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Monday, January 23, 2023

Supreme Court Dismisses Attorney-Client Privilege Case as Improvidently Granted (1/23/2023)

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I recently reported on this blog and my Federal Tax Crimes Blog on the Oral Arguments in In   Re Grand Jury  (Sup Ct. No. 21-1397), docket e...
Friday, January 20, 2023

10th Circuit in Unpublished Opinion Holds § 6751(b)(1) Written Supervisor Approval Must Precede Notice of Deficiency (1/20/23; 1/21/23)

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In Minemyer v. Commissioner (10th Cir. 1/19/23), 10 th Cir. here and TN here  and GS here  ( Unpublished) , The Court key holding is rela...
Thursday, January 19, 2023

On Remand from 6th Circuit, District Court Orders Vacatur of Listed Transaction Notice (1/19/23)

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I have previously written on the Sixth Circuit’s invalidation of an IRS listed transaction Notice (as opposed to regulation).  Sixth Circuit...
Tuesday, January 17, 2023

Supreme Court Denies Certiorari in Oakbrook Land Holdings (1/17/23)

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I have previously discussed the Circuit arguable split between the Eleventh and Sixth Circuits over the procedural validity of the so-called...

On Supreme Court Oral Argument in In Re Grand Jury On Issue of Principal or Significant Purpose for Attorney-Client Privilege (1/17/23)

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Readers of this Federal Tax Procedure Blog may be interested in the following blog entry -  On Supreme Court Oral Argument in In Re Grand Ju...
Monday, January 16, 2023

Further Commotion in Liberty Global Collection Suit Over Whether a Notice of Deficiency Is Required Before Collection Suit (1/16/23; 1/19/23)

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Updated 1/19/23 with Court docket entry stating that the claim Liberty Global wanted to assert should not be filed.  See Comment #2 below. I...
Sunday, January 8, 2023

Fifth Circuit En Banc Reverses the Bump Stock Regulation By Wobbling Around Statutory Interpretation Issues (Including Chevron) (1/8/23)

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In Cargill v. Garland , 57 F.4th 447 (5th Cir. 2023) (en banc), CA5  here  and GS here , the Fifth Circuit reversed the prior panel opinion ...
Saturday, December 17, 2022

Professor Yin Article on the Tax Legislation Process and Legislative History (12/17/22)

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George Yin, a retired UVA law professor (bio here ) has published an article that takes on some of the conventional wisdom of jurists and sc...
Tuesday, December 13, 2022

Tax Court Holds that § 6213(a) Time Deadline for Petitions for Redetermination Is Jurisdictional, Thus Not Subject to Equitable Relief (12/13/22)

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I have not yet written on Hallmark Research Collective v. Commissioner , 159 T.C. 126 (2022)  (unanimous reviewed opinion), TCPamphlet  here...
Saturday, December 10, 2022

Supreme Court Grants Cert in Polselli on Issue of a Collections Summons to Third Party Requires Notice to Taxpayer (12/10/22)

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The Supreme Court granted the petition for writ of certiorari in Polselli v. IRS (Sup. Ct. Case No. No. 21-1599).  The opinion of the Sixth...