Insights

Tax Court in Brief | Sprouse v. Comm’r | Unreported Income, Substantiation, and a Section 6673 Penalty

A Remedy Is Not a Claim | Texas Limitations and Injunctions

Legal Issues for Churches and Other Religious Organizations

Life After IEEPA | The Tariffs That Replaced the Tariffs

The Constitutionality of Tax Foreclosure Sales and the Fifth Amendment’s Requirement for “Just Compensation”

IEEPA Tariff Refunds | How Importers Get Their Money Back

The DOJ’s Fraud Enforcement Expansion

Can You Make the IRS Pay Your Legal Fees?

IEEPA Doesn’t Authorize Tariffs | What the Court Held

What the Government Must Prove in a Structuring Case

Why Form 4 Still Applies After the Texas NFA Injunction

Section 6700 Penalties | Issues & Unique Procedural Hurdles

Challenging Treasury Regulations After Loper Bright

Tax Court in Brief | August 24 – 28, 2026

Tax Court in Brief | Chapin v. Comm’r | Section 183 Horse Breeding, Bank Deposits, and a Split Penalty

Tax Court in Brief | Janangelo v. Comm’r | Civil Fraud Penalties Against an IRS Revenue Agent

Tax Court in Brief | Berenblatt v. Comm’r | Whistleblower Record Supplementation and Grand Jury Secrecy

Civil RICO Elements | Where These Claims Break