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April 21, 2025
|7 min read
Tax Controversy and Litigation Series – Look to Cases from 2024
The year 2024 brought a breadth of noteworthy and significant tax decisions impacting both individual and corporate taxpayers. In the first of a recurring
series, this article discusses tax cases from 2024 that we found intriguing and relevant to taxpayers.
series, this article discusses tax cases from 2024 that we found intriguing and relevant to taxpayers.
October 2, 2023
|4 min read
IRS Backtracks on Penalties and Seeks to Settle Case Involving Backdated Documents
September 14, 2023
|6 min read
Tax Court Reproach of “Cut-and-Paste” Notice Another Blow to IRS Documentation Credibility
A Tax Court Memorandum Opinion expressing no confidence that a “slipshod-cut-and-paste” notice of deficiency was the version of the notice actually sent to
the taxpayer is the latest in a string of rebukes from the Court and Congress questioning the IRS’s ability to retain credible and complete records.
the taxpayer is the latest in a string of rebukes from the Court and Congress questioning the IRS’s ability to retain credible and complete records.
May 2, 2022
|4 min read
On April 21, 2022, the Supreme Court of the United States held in Boechler, P.C. v. Commissioner that the 30-day time limit under Internal Revenue Code
(“I.R.C.” or “Code”) § 6330(d)(1) for a taxpayer to file a petition for a collection due process (“CDP”) hearing with the United States Tax Court is a
non-jurisdictional deadline. The Supreme Court’s holding is significant because, as a non-jurisdictional deadline, I.R.C. § 6330(d)(1)’s 30-day time l...Read more
(“I.R.C.” or “Code”) § 6330(d)(1) for a taxpayer to file a petition for a collection due process (“CDP”) hearing with the United States Tax Court is a
non-jurisdictional deadline. The Supreme Court’s holding is significant because, as a non-jurisdictional deadline, I.R.C. § 6330(d)(1)’s 30-day time l...Read more
About This Blog
Winston & Strawn’s Tax Impacts series features timely updates and insights impacting taxpayers, spanning from federal, international, and state and local tax planning to controversy.
