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NewsFederal Register

Proposed Regulations on Excise Tax for Remittance Transfers Under Section 4475

The Internal Revenue Service’s proposed 1% excise tax on remittance transfers under Section 4475 of the Internal Revenue Code marks a significant expansion of federal tax authority into the cross-border payments sector.

REG–114499–25
NewsFederal Register

Final Regulations on Deduction for Qualified Tips Under Section 224

The IRS has finalized a landmark deduction under the One, Big, Beautiful Bill Act (OBBBA), allowing taxpayers to claim up to $25,000 annually for qualified tips—a provision that reshapes how tipped workers and their employers navigate the tax code.

TD 10044
NewsIRS Bulletin

IRS Releases 2025 Advance Pricing Agreement Report and Updates Fringe Benefits Aircraft Valuation Formula

The Internal Revenue Service issued its 27th annual report on the Advance Pricing and Mutual Agreement (APMA) Program, providing critical insights into transfer pricing enforcement trends for 2025. Announcement 2026-8, released in Bulletin No.

Bulletin No. 2026–16
NewsUS Tax Court

Varian Medical Systems' $60M Deduction Disallowed: Tax Court Upholds IRS on Section 246 Holding Period and Section 245A(d) Computation

The Tax Court’s April 8 ruling in Varian Med. , Inc. & Subs. v. 3 million foreign tax credit disallowance—highlighting the high-stakes transition from the old worldwide tax system to the TCJA’s territorial regime.

8435-23
NewsUS Tax Court

Tax Court Lacks Jurisdiction Over Whistleblower Claim Denied After IRS Classifier Review

S. Tax Court. Pratt’s $10,000 dispute wasn’t just about the money; it was a jurisdictional showdown testing whether the Tax Court could assert authority over the IRS when no administrative or judicial action had been taken against the target taxpayer. C. Circuit’s recent decision in Kennedy v.

27438-21W
NewsIRS Bulletin

IRS Bulletin No. 2026–15: Comprehensive Digest of Key Tax Guidance and Regulatory Updates

The IRS Bulletin No. 2026-15 arrives amid a period of heightened regulatory flux, where long-standing provisions intersect with evolving legislative priorities and emerging economic realities.

Bulletin No. 2026–15

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Featured Analysis

featuredUS District Court

The Systemic Collapse of the Listed Transaction Regime: From Mann to Ryan

The IRS's strategy to combat tax shelters is facing a pincer movement. While Mann and Green Valley forced the agency to use formal regulations, the Ryan challenge now threatens to invalidate those very regulations as arbitrary and capricious.

Ryan LLC v. United States
featured

Law of Tax Penalties

Four recent federal court cases—Mukhi, Silver Moss, Riddle Aggregates, and Schwarzbaum—refine the boundaries of tax penalties, balancing IRS authority against constitutional protections and statutory limits in areas like international reporting, conservation easements, and foreign bank accounts.

featured

Trump 2.0 Cryptocurrency Tax Priorities

The Trump Administration's 2025 cryptocurrency tax framework represents a comprehensive approach to promoting innovation while reducing regulatory barriers, prioritizing individual freedom and self-custody by removing rules that make cold storage and direct ownership of digital assets difficult.

featured

Tariff Case: Delegation Abductio ad Absurdum

2026 will likely see dramatic re-adjustments to the balance of federal authority with serious implications for the IRS

featured8th Circuit Court of Appeals

3M case, 8th Circuit says: "Statutes trump regulations", Applies Loper Bright, and Rejects IRS Position

In a landmark reversal, the Eighth Circuit ruled that the IRS cannot tax income that a taxpayer is legally prohibited from receiving, delivering a major blow to the agency's reallocation authority under Section 482.

3M Company v. Commissioner
featured

Criminal Tax Prosecutions Involving Cryptocurrency: A Comprehensive Case Analysis

An in-depth examination of criminal tax cases involving cryptocurrency and digital assets, including prosecution arguments, defense strategies, and unique case facts. This resource aggregates all known criminal tax prosecutions related to cryptocurrency.

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TaxCourtBlog

The Tax Court Blog provides in-depth US tax court analysis, expert commentary on IRS court cases, and insights for tax professionals and taxpayers.

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Grantor Trusts vs Non-Grantor Trusts: Tax Treatment and Asset Protection

Understanding the critical distinction between grantor and non-grantor trusts, their tax consequences, and the factual elements that determine classification. This guide explores the tradeoffs between tax treatment and asset protection.

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Intentionally Defective Grantor Trust (IDGT): Purpose and Implementation

Understanding Intentionally Defective Grantor Trusts (IDGTs), their purpose in estate planning, and how they are structured to achieve both estate tax exclusion and income tax advantages while maintaining asset protection benefits.

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Probate, Estate Taxes, and Basis Step-Up: Trust and Estate Planning Tradeoffs

Understanding the critical tradeoffs between probate avoidance, estate tax minimization, and basis step-up benefits in trust and estate planning. This guide explores how different strategies balance these competing objectives.

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Smart Contract Trusts: Digital Assets, Blockchain Technology, and Trust Planning

Exploring the emerging intersection of blockchain technology, smart contracts, and trust law. This guide examines how wallet addresses can serve as trust identities, hardware security modules (HSMs) as trustees and beneficiaries, and the tax treatment and asset protection possibilities in the digital asset era.

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Adoption Credit and Exclusion

Tax credit and exclusion for qualified adoption expenses

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Alimony and Separate Maintenance Payments

Tax treatment of alimony payments and separate maintenance payments

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Trade or Business Expense Deductions

Deductions for ordinary and necessary business expenses under Section 162

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