This week we look at:

• Federal Circuit Ruling Finds Limits on Executive Authority to Impose Tariffs Under IEEPA
• Introduction to OBBBA R&E Expenditure Procedures
• Sixth Circuit Realigns on Tax Court Jurisdiction
• Innocent Spouse Relief: Walsh v. Commissioner Overview
• Taxpayer Precluded from Challenging Liability: Sullivan v. Commissioner
• 60-Day IRA Rollover Waiver in a Fraud Scenario

This week we look at:

• Federal Complaint Seeking ERC Refunds: Superior Pediatric Care v. United States
• Proposed Revisions to Partnership Information Reporting for Sales or Exchanges of Interests—Form 8308
• Taxation of Unsolicited Stock Transfers: Analysis of Feige v. Commissioner
• Third-Party Intent and the Indefinite Assessment Period: An Analysis of Murrin v. Commissioner
• The One, Big, Beautiful Bill Act (OBBBA): New Deductions & Energy Credit Modifications
• LLM Limitations in Tax Law: Beyond Memorization

This week we look at:

• Denham Outlines Its Criticisms of the Tax Court’s Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals
• Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner
• Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility
• The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners
• Understanding New Clean Electricity Credit Termination Rules Impact of IRS Notice 2025-42 on Wind and Solar Facilities