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In Apache Corp. v. Commissioner, 165 T.C. ___ No. 11 (11/1325), reviewed opinion, the Court addressed the momentous (to some) issue of whether a taxpayer electing not to carryback some categories of net operating losses (NOLs) can reserve in the election to carryback other categories of NOLs. The opinions in Appache may be viewed on the Tax Court Docket Sheet for Case ...
In Patel v. Commissioner, 165 T.C. ___, No. 10 (11/12/25) (unanimous reviewed opinion), the Tax Court (Judge Jones) applied the interpreted the requirements of the accuracy-related penalty for transactions that lack economic substance, § 6662(b)(6), which applies the economic substance doctrine as codified under I.R.C. § 7701(o). The Opinion (for which there is yet no ...
In Paul Adams Quarrry Trust v. Commissioner, T.C. Memo. 2025-112, GS here [to come] and TN here, the Tax Court (Judge Toro) shot down another bullshit conservatio...
In Cottonpatch Timber Company, LLC v. Commissioner (T.C. No. 26103-22, here, at #54 Order dtd 10/29/25), TN href="https://www.taxnotes.com/research/federal/court-documents/court-opinions-and-orders/tax-court-notes-controlling-precedent-conservation-easement-c...
I am late to post on North Wall Holdings, LLC v. Commissioner, 165 T.C. ___, No. 9 (10/21/25) (reviewed opinion, T.C. Case No. 27773-21, here, at # 50 and GS href="https://scholar.google.com/scholar_case?case=8303173995220595920" target="_blank" rel="no...
