Tax Research Examples

Real Tax research prompts, run end to end in Midpage — each with the full exchange, linked authorities, and citator treatment.

• CDP Jurisdiction After Zuch

  How the Tax Court has applied Commissioner v. Zuch when the IRS abandons a levy mid-proceeding — the Supreme Court’s holding that section 6330 jurisdiction ends once no levy is pursued, dismissals for mootness after abatements and concessions of full payment, the period-by-period operation of the rule when other tax years remain in dispute, the survival of innocent-spouse determinations under section 6015 as an independent jurisdictional grant, and the remission of remaining overpayment claims to refund suits subject to section 7422’s administrative-claim prerequisite.

• Reasonable Cause & Reliance on Advisors

  How courts apply the reasonable-cause exception to accuracy-related penalties when the taxpayer relied on a professional — Boyle’s holding that a missed filing deadline is not excused by reliance on an agent while reliance on substantive tax advice can be, Neonatology’s three-prong test for reasonable reliance, a 2024 decision excusing penalties for taxpayers who relied on a competent in-house accountant for complex net operating loss computations, and 2025 decisions sustaining penalties where the adviser’s competence was unproven or the advice came from promoters of the transaction.

• Conservation Easement Disputes

  The current state of syndicated conservation-easement litigation — the Eleventh Circuit’s holding in Hewitt that the proceeds regulation is procedurally invalid under the APA, the Sixth Circuit’s contrary conclusion in Oakbrook, the Tax Court’s abandonment of Oakbrook in Valley Park Ranch, the setting aside of Notice 2017-10 and its section 6662A penalties in Green Valley Investors and Green Rock, and the valuation trials in Ranch Springs and its successors, where 40% gross-valuation-misstatement penalties attach without a reasonable-cause defense.

• FBAR Willfulness After Bittner

  How courts define willfulness for civil FBAR penalties and how Bittner’s per-report rule reaches pre-2023 conduct — the uniform circuit holding that recklessness satisfies § 5321(a)(5)(C) under Safeco’s objective standard, the Second Circuit’s 2026 decision joining that consensus, the government’s recalculation of stacked per-account non-willful assessments in pending collection actions, and the Eleventh Circuit’s account-by-account calculation of willful penalties under § 5321(a)(5)(D) together with its Excessive Fines Clause holding.

• Anti-Injunction Act After CIC Services

  When the Anti-Injunction Act permits pre-enforcement challenges to IRS reporting requirements after CIC Services — the Supreme Court’s three-factor analysis separating reporting mandates from taxes, the Sixth Circuit’s and Tax Court’s decisions setting aside listed-transaction notices for want of notice and comment, the Eleventh Circuit’s agreement in Green Rock and a district court’s party-specific vacatur in GBX Associates, the First Circuit’s extension to summons-based information gathering, and the decisions holding suits aimed at assessment or collection itself still barred.

• Treasury Regs After Loper Bright

  How courts review Treasury regulations now that Loper Bright has overruled Chevron — the Tax Court’s holding in Varian that Treasury Regulation § 1.78-1 cannot contravene the clear text of the dividends-received provisions, the Eighth Circuit’s best-reading rejection of the blocked-income regulation under section 482 in 3M, the Second Circuit’s conclusion that the section 170 charitable-contribution rule correctly interprets the statute, the Tax Court’s Skidmore-weighted validation of the funded-research regulation, and the preservation of Chevron-era regulatory holdings through statutory stare decisis.