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.
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.
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.
2026 will likely see dramatic re-adjustments to the balance of federal authority with serious implications for the IRS
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.
An in-depth examination of criminal tax cases involving cryptocurrency and digital assets, including prosecution arguments, defense strategies, and unique case facts. This resource aggregates all known criminal tax prosecutions related to cryptocurrency.
Diane Kroupa, a former US Tax Court judge who spent over a decade adjudicating tax disputes, was sentenced to 34 months in prison for conspiring to defraud the United States of $450,000 in taxes—a case that perfectly illustrates the irony of a tax adjudicator becoming a tax evader.
California's proposed billionaire tax and similar state initiatives raise fundamental questions about taxing unrealized gains and wealth. The Supreme Court's decision in Moore v. United States provides crucial—but incomplete—guidance on the constitutional limits of such taxation.
The Tax Court's decision in Varian Medical Systems, Inc. v. Commissioner marks the first application of the Supreme Court's Loper Bright ruling in a tax context, fundamentally altering how courts review IRS regulations and interpret tax statutes.
The Mukhi case requires that penalties be explicitly assessable as a tax by statute. If the penalty is not marked as assessable by statute, then the IRS must sue civilly to collect the penalty. This analysis examines every penalty and whether it is explicitly marked as assessable by statute.
President Donald Trump has reignited a long-dormant debate in American fiscal policy by calling for the potential elimination of the federal income tax, proposing to replace it with revenue from tariffs on imports.