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Featured Analysis

featuredUS District Court

The Systemic Collapse of the Listed Transaction Regime: From Mann to Ryan

The IRS's strategy to combat tax shelters is facing a pincer movement. While Mann and Green Valley forced the agency to use formal regulations, the Ryan challenge now threatens to invalidate those very regulations as arbitrary and capricious.

Ryan LLC v. United States
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Law of Tax Penalties

Four recent federal court cases—Mukhi, Silver Moss, Riddle Aggregates, and Schwarzbaum—refine the boundaries of tax penalties, balancing IRS authority against constitutional protections and statutory limits in areas like international reporting, conservation easements, and foreign bank accounts.

featured

Trump 2.0 Cryptocurrency Tax Priorities

The Trump Administration's 2025 cryptocurrency tax framework represents a comprehensive approach to promoting innovation while reducing regulatory barriers, prioritizing individual freedom and self-custody by removing rules that make cold storage and direct ownership of digital assets difficult.

featured

Tariff Case: Delegation Abductio ad Absurdum

2026 will likely see dramatic re-adjustments to the balance of federal authority with serious implications for the IRS

featured8th Circuit Court of Appeals

3M case, 8th Circuit says: "Statutes trump regulations", Applies Loper Bright, and Rejects IRS Position

In a landmark reversal, the Eighth Circuit ruled that the IRS cannot tax income that a taxpayer is legally prohibited from receiving, delivering a major blow to the agency's reallocation authority under Section 482.

3M Company v. Commissioner

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TaxCourtBlog

The Tax Court Blog provides in-depth US tax court analysis, expert commentary on IRS court cases, and insights for tax professionals and taxpayers.

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Grantor Trusts vs Non-Grantor Trusts: Tax Treatment and Asset Protection

Understanding the critical distinction between grantor and non-grantor trusts, their tax consequences, and the factual elements that determine classification. This guide explores the tradeoffs between tax treatment and asset protection.

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Intentionally Defective Grantor Trust (IDGT): Purpose and Implementation

Understanding Intentionally Defective Grantor Trusts (IDGTs), their purpose in estate planning, and how they are structured to achieve both estate tax exclusion and income tax advantages while maintaining asset protection benefits.

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Probate, Estate Taxes, and Basis Step-Up: Trust and Estate Planning Tradeoffs

Understanding the critical tradeoffs between probate avoidance, estate tax minimization, and basis step-up benefits in trust and estate planning. This guide explores how different strategies balance these competing objectives.

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Smart Contract Trusts: Digital Assets, Blockchain Technology, and Trust Planning

Exploring the emerging intersection of blockchain technology, smart contracts, and trust law. This guide examines how wallet addresses can serve as trust identities, hardware security modules (HSMs) as trustees and beneficiaries, and the tax treatment and asset protection possibilities in the digital asset era.

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Adoption Credit and Exclusion

Tax credit and exclusion for qualified adoption expenses

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Alimony and Separate Maintenance Payments

Tax treatment of alimony payments and separate maintenance payments

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Trade or Business Expense Deductions

Deductions for ordinary and necessary business expenses under Section 162

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