Practice Area Spotlight

Tax

Tax lawyers use Midpage to research federal and state tax disputes — from audit and administrative appeal through litigation and collection. The statutes, IRS guidance, and case law behind that work are collected below.

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How Tax Lawyers Use Midpage

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CDP Jurisdiction After ZuchSummarize how the Tax Court has applied Commissioner v. Zuch when the IRS abandons a levy mid-proceeding, including refund-claim spillover effects.Reasonable Cause & Reliance on AdvisorsDraft a penalty-defense section applying Boyle’s limits on reliance on advisors, with recent accuracy-related penalty outcomes.Conservation Easement DisputesSummarize the current state of syndicated conservation-easement litigation, including proceeds-regulation challenges and valuation penalties.FBAR Willfulness After BittnerHow have courts defined willfulness for FBAR penalties, and how is the per-report rule of Bittner applied to pre-2023 conduct?Anti-Injunction Act After CIC ServicesWhen can pre-enforcement challenges to IRS reporting requirements proceed despite the AIA? Collect post-CIC Services decisions.Treasury Regs After Loper BrightWhich Treasury regulations have been invalidated or upheld since Chevron was overruled? Collect decisions and the interpretive methods courts applied.

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Core Tax Collections

The statutes, agency guidance, and courts behind tax practice.

The provisions of the Internal Revenue Code that structure deficiency, collection, refund, and penalty litigation — plus the Title 31 FBAR statutes and the Title 28 refund-jurisdiction grant.

Deficiency procedures Notices of deficiency and the 90-day Tax Court petition window, with restrictions on assessment	26 U.S.C. §§ 6212–6213
Limitations on assessment The 3-year baseline, the 6-year substantial-omission rule, and the unlimited fraud exception	26 U.S.C. § 6501
Partnership audit regime (BBA) Centralized partnership-level determinations, imputed underpayments, and push-out elections	26 U.S.C. §§ 6221–6241
Collection due process Lien and levy hearings and Tax Court review — the statute construed in Boechler and Zuch	26 U.S.C. §§ 6320, 6330
Trust fund recovery penalty Responsible-person liability for withheld employment taxes — willfulness and the 100% penalty	26 U.S.C. § 6672
Refund claims & limitations The 3-year/2-year claim deadlines, lookback caps, and the claim-first prerequisite to suit	26 U.S.C. §§ 6511, 7422
Refund jurisdiction Concurrent district-court and Court of Federal Claims jurisdiction over refund suits	28 U.S.C. § 1346(a)(1)
Accuracy-related & fraud penalties The 20% and 40% penalties and the § 6664(c) reasonable-cause and good-faith defense	26 U.S.C. §§ 6662–6664
Reportable-transaction penalties Listed-transaction disclosure penalties — the enforcement backdrop of CIC Services	26 U.S.C. § 6707A
Foreign information returns Form 5471 reporting for controlled foreign entities — the assessable-penalty question in Farhy	26 U.S.C. § 6038
FBAR reporting & penalties The Bank Secrecy Act reporting duty and the per-report penalties construed in Bittner	31 U.S.C. §§ 5314, 5321
IRS summons authority Examination of books and witnesses — the summons power and its enforcement limits	26 U.S.C. § 7602
Anti-Injunction Act The bar on suits restraining assessment or collection, as narrowed by CIC Services	26 U.S.C. § 7421
Economic substance codified The two-prong economic-substance test and its strict-liability penalty consequences	26 U.S.C. § 7701(o)
Tax Court jurisdiction & appeals The Tax Court’s jurisdictional grant and circuit review — venue follows the taxpayer under Golsen	26 U.S.C. §§ 7442, 7482
Criminal tax Evasion and false-return offenses — governed by Cheek’s subjective willfulness standard	26 U.S.C. §§ 7201, 7206

Treasury’s practice rules and Treasury/IRS rulemakings as published in the Federal Register — the codified 26 CFR collections are on the way.

Income tax regulationsComing soon The substantive income tax regulations under subtitle A	26 CFR Part 1
Procedure & administrationComing soon Assessment, collection, CDP hearing, and summons procedure rules	26 CFR Part 301
Estate & gift tax regulationsComing soon Valuation and transfer-tax rules behind Connelly-type disputes	26 CFR Parts 20, 25
Practice before the IRS (Circular 230) Who may practice, duties and restrictions, written-advice standards, and sanctions	31 CFR Part 10
Federal Register Rules Treasury and IRS rulemakings — proposed, temporary, and final regulations as published	1994–present

The Internal Revenue Bulletin guidance and taxpayer-specific rulings that frame audit positions and litigation — searchable alongside the case law.

Revenue Rulings The Service’s published positions applying the law to stated facts	Rulings
Private Letter Rulings & TAMs Taxpayer-specific rulings and technical advice released under § 6110	Rulings
Revenue Procedures Administrative procedure — letter-ruling practice, safe harbors, and annual user-fee schedules	Guidance
IRS Notices Interim guidance and transaction-of-interest designations — the vehicle at issue in CIC Services	Guidance
IRS Announcements Public statements of Service position and corrections published in the IRB	Guidance
Chief Counsel Advice Field advice and generic legal advice memoranda from the Office of Chief Counsel	Guidance
Internal Revenue ManualComing soon The Service’s operating procedures for examination, collection, and appeals	Guidance

The forums where tax disputes are litigated — deficiency, refund, and collection cases follow different paths to review.

Appellate

U.S. Supreme Court; all 13 federal circuits — venue follows the taxpayer’s residence under the Golsen rule; the Federal Circuit hears Court of Federal Claims appeals

Trial

U.S. Tax Court — published T.C. and Memorandum opinions in deficiency and CDP cases; U.S. District Courts and the Court of Federal Claims — refund suits; bankruptcy courts — tax claims and discharge disputes

State

State appellate courts and tax tribunals — SALT controversies from Wayfair-era nexus disputes to residency and apportionment fights, across all 50 states

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Key Cases

The controlling authorities — linked to full text, treatment, and citing decisions in Midpage.

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Tax

How Tax Lawyers Use Midpage

Core Tax Collections

Key Cases

United States v. Boyle

Cheek v. United States

Mayo Foundation v. United States

South Dakota v. Wayfair, Inc.

CIC Services, LLC v. IRS

Boechler, P.C. v. Commissioner

Bittner v. United States

Moore v. United States

Connelly v. United States

Loper Bright Enterprises v. Raimondo

Corner Post, Inc. v. Board of Governors

Commissioner v. Zuch

Farhy v. Commissioner

Research tax law with Midpage.