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Articles revisit whether Treasury regulations comply with the APA and how TCJA regulations fare under Loper Bright, alongside broader analysis of legislative versus interpretive regulations and the limits of administrative deference in tax litigation.
Draft a post from this →Multiple tax-law articles discuss the IRS replacing or phasing out First Time Abate with a new automatic penalty relief/exemption framework, with practitioners debating whether the relief is truly automatic and how it changes Form 843 and penalty-abatement strategy.
Draft a post from this →Recent practitioner coverage focuses on IRS Notice 2026-40 and its transitional guidance for the updated Qualified Opportunity Zone regime under §§ 1400Z-1 and 1400Z-2, including how firms should interpret the transition rules.
Draft a post from this →A cluster of practitioner resources covers reasonable cause abatement, Currently Not Collectible status, IRS notice-response workflows, and Form 843 guidance, showing firms updating internal playbooks for taxpayer relief and collection defense.
Draft a post from this →A case analysis of HBM Holdings Co. v. Commissioner examines predecessor losses, the lonely parent rule, and how courts apply economic reality concepts in tax controversy.
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