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Federal
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April 07, 2026
Partnership Wants Tax Court To Reconsider Basis Question
A partnership asked the U.S. Tax Court to reconsider its finding that a company contributing a promissory note for a stake in the partnership had zero basis in the note, saying basis must be determined when a note is contributed, not at its conception.
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April 07, 2026
Partnership Tells Tax Court Settlement Was Long-Term Gain
The $4 million payment a California partnership received in 2021 as part of a settlement should be characterized as long-term gain and not ordinary income, it told the U.S. Tax Court, saying its issue is the same as that in pending cases for prior years.
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April 07, 2026
Sen. Justice Challenges IRS Over $3.6M Tax Penalty
West Virginia Sen. Jim Justice and his wife challenged a $3.6 million tax penalty for claiming what the Internal Revenue Service said was an erroneous refund for $18 million, telling the U.S. Tax Court they were improperly prevented from appealing the fine and can't afford to pay.
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April 07, 2026
IRS Updates Foreign Housing Expense Limits For 2026
The Internal Revenue Service released adjustments Tuesday to the limitation on foreign housing expense deductions and exclusions for 2026.
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April 07, 2026
IRS Met Legal Requirements When Asking For Extensions
The Internal Revenue Service followed the law when asking taxpayers to extend the statute of limitations for assessments, the Treasury Inspector General for Tax Administration said in a report released Tuesday.
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April 07, 2026
Floridian Says Jury Was Required Before $20M FBAR Fine
A dual U.S.-German citizen urged a Florida federal court to reject a magistrate judge's recommendation to uphold a nearly $20 million tax judgment for undisclosed foreign bank account information, contending the judge failed to recognize a recent change in the law about access to jury trials.
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April 07, 2026
DOJ Backs Wrong View Of Accounting Error, 11th Circ. Told
A hedge fund manager challenging the denial of a $1.9 million tax refund related to his private jet told the Eleventh Circuit that the federal government is wrongly parroting a lower court's unreasonable approach to the accounting error underlying the dispute.
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April 06, 2026
IRS' Proposed Voluntary Disclosure Rule Could Be Dissuasive
The IRS has proposed relaxing the 75% civil fraud penalty for participants in its voluntary disclosure program, but a corresponding 90-day deadline for complying with all payment and filing requirements could discourage some taxpayers from coming forward.
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April 06, 2026
Self-Employment Earnings Not Partnership Item, 1st Circ. Told
An energy investment firm urged the First Circuit to disregard a 2009 Federal Circuit decision barring individual partners from seeking refunds of a partnership's income taxes, arguing the opinion has no bearing on its own suit challenging self-employment taxes on individual income.
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April 06, 2026
BNY, Robinhood To Help Roll Out Trump Accounts
The Bank of New York Mellon Corp. will be the federal government's financial agent in helping implement the new tax-advantaged brokerage accounts for children called Trump accounts, the U.S. Treasury Department said Monday.
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April 06, 2026
IRS Expands Business Tax Accounts To Tax-Exempt Groups
The IRS has expanded its online self-service business tax accounts, making them available to tax-exempt organizations, partnerships and federal, state, local and tribal governments, the agency announced Monday.
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April 06, 2026
Activewear Co. Fabletics Sued Again For Tariff Refunds
Fabletics, the activewear company cofounded by actress Kate Hudson, was hit with a proposed class action in California federal court Friday alleging it is improperly pocketing tariff surcharges from customers and is refusing to commit to refunds, weeks after a similar suit was filed in Illinois state court.
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April 06, 2026
IRS Lays Out Opportunity Zone Nominating Guidelines
The Internal Revenue Service released guidance Monday describing the nomination process and eligibility requirements for designated qualified opportunity zones and identifying a list of qualifying areas.
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April 06, 2026
IRS Gets Penalty Approval Wrong, Justices Told
The Internal Revenue Service has improperly interpreted a requirement that an agency supervisor must approve tax penalties before they're asserted against a taxpayer, a couple told the U.S. Supreme Court, urging it to overturn an Eleventh Circuit decision slapping them with $345,000 in accuracy-related penalties.
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April 06, 2026
Int'l Tax In March: Tariff Refunds Coming Amid New Disputes
Tariffs dominated the headlines in March, with the process for refunding those illegally imposed under the International Emergency Economic Powers Act being set up — and customers demanding their cut from businesses. Here, Law360 looks at these and other international tax developments from last month.
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April 06, 2026
Top Court Paves Way To Wipe Out Pol's Bribery Conviction
The U.S. Supreme Court on Monday vacated an appeals court's decision to uphold the conviction of a pardoned former Cincinnati council member for bribery and attempted extortion, effectively greenlighting federal prosecutors' motion to toss the case.
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April 06, 2026
Justices Pass On Oklahoma Tribal Tax Case
The U.S. Supreme Court declined Monday to review an Oklahoma high court ruling that denied tax-exempt status to a member of the Muscogee Creek Nation.
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April 03, 2026
Man Denies Owing Gov't $19M In Biofuel Tax Credit Fraud
A businessman told a Utah federal court that he shouldn't need to pay over $19 million for a forfeited loan from a company central to a $511 million biofuel tax credit fraud because the government's calculations are unjust and a government asset tricked him into withholding payment.
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April 03, 2026
Law360 Announces The Members Of Its 2026 Editorial Boards
Law360 is pleased to announce the formation of its 2026 Editorial Advisory Boards.
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April 03, 2026
Feds Fight Atty's Bond Request Amid $22M Tax Fraud Appeal
A North Carolina federal court should reject a lawyer's bid to remain free on bail while she appeals her conviction for helping perpetrate a $22 million tax fraud scheme because she didn't show that her appeal is likely to change her conviction, federal prosecutors said.
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April 03, 2026
Sanctioned Ex-Broker Pushes To Keep IRS Records Suit Alive
The IRS should not be allowed to withhold records of its investigation into an ex-broker sanctioned by the Financial Industry Regulatory Authority for hiding $1.7 million in tax liens, he told a North Carolina federal court Friday, urging it to let his case against the tax agency proceed.
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April 03, 2026
Taxation With Representation: Cleary, Hogan Lovells, Wachtell
In this week's Taxation With Representation, spice maker McCormick acquires Unilever's foods business, wholesale restaurant food distributor Sysco buys Jetro Restaurant Depot, and private equity giant KKR closes a fund focused on investments in North America.
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April 03, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included the agency's request for suggestions on what to prioritize in an upcoming guidance plan.
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April 03, 2026
Clean Energy Tax Credits Could Gain Ground In Tax Planning
Discounted pricing and risk-limiting contracts are driving large companies to buy clean energy tax credits to lower their IRS bills, a move experts said could become standard in corporate tax planning.
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April 02, 2026
Judge Keeps IRS, Booz Allen In Lawsuit Over Tax Data Leak
A class action against the federal government and contractor Booz Allen Hamilton seeking to hold them accountable for the unauthorized disclosure of a trove of wealthy people's tax returns by a worker on the job with the IRS can move forward, a Maryland federal judge said.
Expert Analysis
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How Attys Can Use A Therapy Model To Help Triggered Clients
Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.
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3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
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IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
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Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
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Notable Q1 Updates In Insurance Class Actions
The first quarter of 2025 was filled with the refinement of old theories in the property and casualty space, including in vehicle valuation, time to seek appraisal and materials depreciation, says Mathew Drocton at BakerHostetler.
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Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
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E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
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Maximizing Exemptions Before TCJA Rides Into The Sunset
Excerpt from Practical Guidance
Individuals with taxable estates can optimize the benefits of estate planning strategies like spousal lifetime access trusts by setting them up before increases in estate and gift tax exemptions under the 2017 Tax Cuts and Jobs Act sunset in January, say attorneys at Katten.