Federal
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November 07, 2025
DOJ Backs Trump In NY False-Records Conviction Appeal
The U.S. Department of Justice is throwing its support behind President Donald Trump's effort to overturn his New York criminal conviction for falsifying business records, filing a proposed amicus brief on Friday citing the U.S. Supreme Court's landmark 2024 decision "defining the contours of a president's federal constitutional immunity from criminal prosecution."
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November 07, 2025
Wyden, Warren Flag IRS CEO's Fiserv Tenure In Probe
Two Senate Finance Committee members said they are investigating Internal Revenue Service CEO Frank Bisignano's conduct in his previous position as Fiserv Inc.'s CEO, saying the financial setbacks the company has faced this year raise questions about his ability to serve as a key IRS official.
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November 07, 2025
Taxation With Representation: Kirkland, Cravath, Paul Weiss
In this week's Taxation With Representation, consumer products giant Kimberly-Clark acquires Tylenol maker Kenvue, shale producers SM Energy and Civitas Resources announce a merger, and power management company Eaton buys Boyd Corp.'s thermal business.
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November 06, 2025
Goldstein Loses Bid To Trim Tax Charges Before Trial
A Maryland federal judge Thursday handed SCOTUSblog co-founder Tom Goldstein a series of losses on pre-trial motions aimed at trimming the 22 federal tax charges he'll face at trial next year, ruling that many of the motions involved factual disputes fit for trial and keeping the government's case intact.
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November 06, 2025
Tax Court OKs Disallowance Of Unverified Litigation Fees
The IRS correctly determined that a woman who'd been at odds with her various attorneys — having filed breach of contract suits against two separate legal teams — inadequately justified her claimed $28,000 deduction for legal expenses, the U.S. Tax Court said Thursday.
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November 06, 2025
Whistleblower Entitled To Award For $31M Tip, DC Circ. Told
The U.S. Tax Court wrongly denied a whistleblower award to a woman who said she helped the Internal Revenue Service assess more than $31 million in corporate income, her supporter told the D.C. Circuit, saying the court allowed the agency to omit relevant information it was required to provide.
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November 06, 2025
IRS Microcaptive Reporting Rules Suit Can Move Forward
A global tax services provider can move forward with its suit against the IRS to vacate tax reporting rules for microcaptive insurance companies, a Texas federal court said, finding the company had a stake in the challenge and a right to bring the case.
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November 06, 2025
No $22M Break For Real Estate Partnership, 6th Circ. Affirms
An Ohio real estate partnership cannot claim a $22 million charitable tax deduction on a 2016 preservation easement, the Sixth Circuit found, affirming the U.S. Tax Court and Internal Revenue Service's conclusions that the partnership grossly misstated the value of the donated historic building.
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November 06, 2025
Tax Court Says IRS Took Too Long To Ax Easement Deduction
The Internal Revenue Service failed to timely disallow a charitable deduction related to a company's conservation easement donation, the U.S. Tax Court said, throwing out a partnership adjustment by the agency.
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November 06, 2025
2nd Circ. Orders New Look At Trump's Hush Money Case
In a published opinion, the Second Circuit on Thursday ordered a federal district judge to take a fresh look at President Donald Trump's attempt to move his New York hush money conviction to federal court, citing the U.S. Supreme Court's 2024 presidential immunity ruling as grounds for reconsidering the case.
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November 05, 2025
Judge Questions Transfer Of Eaton's $14B Foreign Asset
A U.S. Tax Court judge questioned a former Eaton Corp. official Wednesday about the company's decision to restructure the ownership of a valuable foreign subsidiary when it inverted in 2012, noting that the move placed a $14 billion asset out of the U.S. company's reach.
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November 05, 2025
IRS Direct File Will Not Be Offered In 2026, States Confirm
State revenue agencies confirmed Wednesday that the Internal Revenue Service has informed them that its free online tax preparation tool, Direct File, will not be offered for the 2026 filing season and potentially other years.
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November 05, 2025
IRS Layoffs Include Over 500 Exam Employees, Docs Show
The federal workers laid off during the government shutdown include more than 500 people in the exam and collections section of the IRS responsible for enforcing tax laws, a federal employee told a California federal court in a lawsuit over the firings.
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November 05, 2025
Docs Show IRS Improperly Shared Data With ICE, Groups Say
Documents submitted by the U.S. government to a D.C. federal court show the IRS violated taxpayer privacy laws by sharing individuals' addresses with ICE despite its requests lacking required information and by accepting an unreasonable explanation about why the information was requested, several groups said.
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November 05, 2025
Ex-Mashpee Tribal Leader Gets 3.5 Years For Casino Bribes
The former chair of the Mashpee Wampanoag Tribe on Wednesday was sentenced to a 42-month prison term for orchestrating a bribery scheme tied to the tribe's $1 billion casino project, as a Massachusetts federal judge chastised him for characterizing his yearslong conduct as "mistakes."
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November 05, 2025
Fed. Circ. Skeptical Of Family Trusts' Tax Fraud Case
The Federal Circuit seemed skeptical Wednesday of an $80 million tax challenge by a group of family trusts that claimed they were unfairly stuck with tax liabilities after being duped into selling assets to a fraudster who then engaged in abusive tax shelter transactions behind their backs.
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November 05, 2025
Justices Skeptical About Trump's Emergency Tariff Authority
Several U.S. Supreme Court justices asked the government to defend why well-established judicial doctrines shouldn't limit President Donald Trump's tariffs imposed under the International Emergency Economic Powers Act during oral arguments Wednesday, casting doubt on whether they believe the law provides that kind of authority.
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November 05, 2025
IRS Provides Penalty Relief For 2025 Tips, OT Reporting
The Internal Revenue Service will treat the 2025 tax year as a transition period for enforcement and administration of the information reporting requirements for the new deductions for tips and overtime, according to guidance released Wednesday.
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November 04, 2025
Malawi Asks Judge To Undo Halt Of Gem Export Tax Probe
Malawi asked a Washington federal judge to reconsider his recent decision to bar the country from pursuing discovery against a gemstone company that it alleges partnered with a mining outfit to dodge billions of dollars in taxes and export royalties.
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November 04, 2025
Former Eaton CFO Says Bond Investors Needed Reassurance
Eaton Corp.'s former chief financial officer chronicled on Tuesday the company's efforts to finance its 2012 acquisition of Ireland-based Cooper Industries, describing an atmosphere of leery bond investors after the Great Recession of 2008, on the second day of the company's U.S. Tax Court trial.
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November 04, 2025
Tax Court Blocks Ariz. Salesman's Business Deductions
The U.S. Tax Court on Tuesday rejected a series of business deductions claimed by an Arizona man working in outside sales and affirmed penalties against him for substantially understating his taxes.
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November 04, 2025
3M Ruling Highlights Loper Bright's Reach In Axing Tax Regs
A U.S. Supreme Court ruling that gutted deference to agencies took center stage in the Eighth Circuit's recent decision that backed 3M's challenge to transfer pricing rules, signaling the strict statutory analysis that courts may now apply to tax regulations.
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November 04, 2025
Ga. Biz Asks Tax Court To Block IRS Easement Changes
A Georgia company asked the U.S. Tax Court to reverse the Internal Revenue Service's adjustments to a claimed noncash charitable contribution for a $61 million conservation easement donation and rule that the company's filing was accurate, according to a petition released Tuesday.
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November 04, 2025
Developer Seeks To Restore Nixed $29M Easement Deduction
The Internal Revenue Service failed to explain its rejection of a $29 million charitable tax deduction claim for an Alabama-based developer's 2016 conservation easement donation to a regional water district, the developer told the U.S. Tax Court as it challenged the decision.
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November 04, 2025
Tax Court Affirms Rejection Of Co.'s Settlement Offer
The Internal Revenue Service did not abuse its discretion in rejecting an offer from a small business to settle its tax debt, the U.S. Tax Court said Tuesday, finding that the company never submitted financial documents the agency needed to accept the deal.
Expert Analysis
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Adapting To Private Practice: 3 Tips On Finding The Right Job
After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.
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Painting Makes Me A Better Lawyer
Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.
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Compliance Pointers Amid Domestic Terrorism Clampdown
A recent presidential memorandum marks a shift in federal domestic-terrorism enforcement that should prompt nonprofits to enhance diligence related to grantees, vendors and events, and financial institutions to shore up their internal resources for increased suspicious-activity monitoring and reporting obligations, say attorneys at Morgan Lewis.
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Trump Tax Law Has Mixed Impacts On Commercial Real Estate
The One Big Beautiful Bill Act brings sweeping changes to the real estate industry — and while the permanency of opportunity zones and bonus depreciation creates predictability for some taxpayers, sunsetting incentives for renewable energy projects will leave others with hard choices, says Jordan Metzger at Cole Schotz.
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Protecting Sensitive Court Filings After Recent Cyber Breach
In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.
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What Ethics Rules Say On Atty Discipline For Online Speech
Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.
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2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers
Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.
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Junior Attys Must Beware Of 5 Common Legal Brief Mistakes
Excerpt from Practical Guidance
Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.
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Digital Asset Report Opens Doors For Banks, But Risks Linger
A recent report from a White House working group discussing digital asset market structure signals how banks may elect to expand into digital asset custody, trading and related services in the years ahead, but the road remains layered with challenges, say attorneys at Foley & Lardner.
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Power To The Paralegals: How And Why Training Must Evolve
Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.
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5 Real Estate Takeaways From Trump's Sweeping Tax Law
Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.
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Evaluating The Current State Of Trump's Tariff Deals
As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.
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How Hyperlinks Are Changing E-Discovery Responsibilities
A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.