Insights

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

Houston Trade-Secret Investigation Puts Restructuring and Offboarding Controls Back in the Spotlight

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

IRS Penalties Are Changing | What Taxpayers Should Know

Writs of Execution in Texas

Tax Court in Brief | August 17 – 21, 2026

The Golsen Rule: Why Your Circuit Decides Your Tax Case