Federal
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May 07, 2025
Tax Court Rejects Couple's Case For Lacking Evidence
A couple who challenged what the Internal Revenue Service said was their more than $650,000 in tax debt provided no evidence that the number was wrong, the U.S. Tax Court said in a bench opinion released Wednesday.
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May 07, 2025
11th Circ. Backs Frivolous Argument Ruling Against Teacher
A Georgia high school teacher who claimed that he didn't have to pay taxes on his salary and that income taxes are unconstitutional must pay $25,000 in court sanctions under an Eleventh Circuit ruling affirming a U.S. Tax Court decision.
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May 07, 2025
Don't Scrap US-China Tax Treaty, Biz Groups Tell Treasury
Business lobbying groups have urged the U.S. Treasury Department to reject the White House's plans to scrutinize the U.S.-China tax treaty, warning that scrapping the accord would lead to higher Chinese taxes on U.S. companies.
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May 07, 2025
Feds Seek 13 Years In Avenatti's California Resentencing
California federal prosecutors asked a judge Wednesday to sentence Michael Avenatti to 160 months in prison for tax fraud and stealing from clients, to be served atop the five-year term imposed in a pair of New York cases where Avenatti was convicted of trying to extort Nike Inc. and defrauding former client Stormy Daniels.
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May 07, 2025
6th Circ. Skeptical Of US In Tax Court Deadline Case
Sixth Circuit judges expressed skepticism of the U.S. government's claim that the 90-day deadline to petition the U.S. Tax Court is inflexible, with one judge saying during oral arguments Wednesday in a woman's case challenging the rule that the U.S. Supreme Court seemed to back her.
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May 07, 2025
Device Seller Asks For Probation In $2.4M Tax Evasion Case
The septuagenarian owner of a Florida medical device company who pled guilty to evading $2.4 million in taxes asked a federal district court Wednesday for his sentence to entail home probation and not prison, given his health challenges and payments he already made to the Internal Revenue Service.
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May 07, 2025
IRS To Open Applications For Low-Income Tax Clinic Grants
The Internal Revenue Service will begin accepting applications May 15 for its grant program for organizations providing tax services to low-income people or people who speak English as a second language, it announced Wednesday.
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May 06, 2025
Fed. Circ. Agrees Plane Taxability Patent Doesn't Fly
The Federal Circuit on Tuesday refused to revive an Ohio company's patent that covers using Federal Aviation Administration data to determine "the taxability status of aircraft," agreeing that it covered subject matter that isn't patentable.
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May 06, 2025
Tax Court Erred In Slashing $23M Easement, 11th Circ. Told
A partnership told the Eleventh Circuit that the U.S. Tax Court erred in substantially reducing its claim to a $23 million conservation easement tax deduction, arguing the decision was tainted by error-riddled criteria used by the IRS to value the property.
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May 06, 2025
Military Moving-Cost Deduction Nixed For Civilian Contractor
A civilian contractor for the U.S. Air Force cannot deduct her moving expenses because she is not considered a member of the military for purposes of the deduction, the U.S. Tax Court said in a bench opinion released Tuesday.
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May 06, 2025
Actor Voight, Film Biz Adviser To Trump, Floats Tax Incentives
Actor Jon Voight, whom President Donald Trump tapped as an adviser on the Hollywood film industry, told Trump that tax incentives, international treaties and limited tariffs could revitalize production, while California Gov. Gavin Newsom separately floated a $7.5 billion federal film tax credit, according to statements shared Tuesday with Law360.
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May 06, 2025
Stationery Co. Fights Bid To Move Tariff Case To Trade Court
The U.S. Court of International Trade does not have exclusive jurisdiction to hear disputes over President Donald Trump's global tariffs, a stationery company told a Florida federal court Monday in opposing the administration's bid to transfer to the suit.
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May 06, 2025
IRS Narrows Benefit Plan Sponsors Subject To New Rules
The Internal Revenue Service on Tuesday narrowed the group of defined benefit plan sponsors that will be subject to certain requirements related to agency approval to use mortality tables that start in January.
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May 06, 2025
Bessent Eyes IRS' Technology Budget For Major Cuts
The Internal Revenue Service must cut its bloated technology budget and decrease the agency's overall spending, U.S. Treasury Secretary Scott Bessent told a House Appropriations panel Tuesday.
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May 06, 2025
Eversheds Sutherland Brings On EY Tax Pro In Atlanta
Eversheds Sutherland has added a former EY senior manager of international tax and transaction services to its Atlanta office, further strengthening its tax practice after adding a dozen tax controversy attorneys from Chamberlain Hrdlicka White Williams & Aughtry PC in March, the firm announced Tuesday.
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May 06, 2025
4th Circ. Seems Split On BofA's Post-Merger Tax Offset Claims
The Fourth Circuit seemed split Tuesday on whether Bank of America should be able to use its tax overpayments to offset interest on tax underpayments by companies that merged into it, with one judge pressing the government to respond to what he described as the bank's "common sense" argument in the $163 million case.
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May 05, 2025
Credit Suisse To Pay Feds $510.6M For Helping Hide Assets
Credit Suisse Services AG has agreed to shell out more than $510 million under agreements with federal prosecutors in which the company admitted to helping customers hide more than $4 billion from the IRS in hundreds of offshore accounts, the U.S. Department of Justice announced Monday.
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May 05, 2025
Feds Say Calif. Tribe's Challenge To Cig Ruling Is 'Fruitless'
The federal government is urging a California federal court not to pause a ruling affirming the Bureau of Alcohol, Tobacco, Firearms and Explosives' decision to place a native tribe on a noncompliance list over cigarette sales, saying the tribe shouldn't be able to upend the status quo as it pursues a "fruitless" appeal to the Ninth Circuit.
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May 05, 2025
Trump Seeks 100% Tariff On Foreign-Made Movies
President Donald Trump asked his administration to place a 100% tariff on foreign-made movies, with a spokesperson telling Law360 on Monday that a final decision on the plan hadn't been made.
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May 05, 2025
Minn. Tribe Looks To Weigh In On 3,000-Acre Land Trust Row
The Mille Lacs Band of Ojibwe has asked a Minnesota federal judge to let it file a friend of the court brief in a county's case claiming the U.S. government wrongly accepted more than 3,000 acres of land into trust for the tribe.
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May 05, 2025
Trump Admin Defends Tariff Power In Toy-Makers' Challenge
President Donald Trump's administration urged a D.C. federal court to deny a request by toy companies to halt global tariffs, arguing the government is authorized to impose trade measures under the International Emergency Economic Powers Act.
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May 05, 2025
IRS Audit Staff Slashed From Layoffs, Voluntary Resignations
Layoffs and voluntary resignations at the Internal Revenue Service have significantly reduced the agency's revenue agents responsible for conducting audits, the Treasury Inspector General for Tax Administration said Monday.
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May 05, 2025
Tax Evader Can't Fight Related Taxes, Court Says
A South Dakota business owner who admitted to hiding income from the Internal Revenue Service cannot challenge the $120,000 the agency claims he owes in additional taxes for fraudulently failing to file returns, the U.S. Tax Court ruled Monday.
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May 05, 2025
Clifford Chance Adds Paul Weiss Exec Compensation Atty In NY
Clifford Chance LLP has added a Paul Weiss Rifkind Wharton & Garrison LLP transactional attorney in New York as co-chair of its U.S. executive compensation practice, the firm announced Monday.
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May 05, 2025
Tax Court Tosses Grandmother's Levy Challenge
The U.S. Tax Court tossed Monday a levy challenge by an Alabama woman who said she was the sole caregiver for her five grandchildren, ruling that she had already received the tax relief she sought when the IRS decided not to collect her overdue taxes.
Expert Analysis
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Notable Q1 Updates In Insurance Class Actions
The first quarter of 2025 was filled with the refinement of old theories in the property and casualty space, including in vehicle valuation, time to seek appraisal and materials depreciation, says Mathew Drocton at BakerHostetler.
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The Benefits Of Aligning States On Legal Paraprofessionals
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
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E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
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Maximizing Exemptions Before TCJA Rides Into The Sunset
Excerpt from Practical Guidance
Individuals with taxable estates can optimize the benefits of estate planning strategies like spousal lifetime access trusts by setting them up before increases in estate and gift tax exemptions under the 2017 Tax Cuts and Jobs Act sunset in January, say attorneys at Katten.
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A Cold War-Era History Lesson On Due Process
The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.
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How BigLaw Executive Orders May Affect Smaller Firms
Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.
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Lawsuits Shouldn't Be Shadow Assets For Foreign Capital
Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.
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How To Accelerate Your Post-Attorney Career Transition
Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.
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Tariffs And FCA Create Perfect Storm For Importers
The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.
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US Reassessment Of OECD Tax Deal Is Right Move
The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.