Resources

Among the many administrative rules and policies that taxpayers must often contend with is the Texas Comptroller’s 5% test. It comes up in different contexts and, when an auditor mentions this test, it often results in an...

One of the most common issues we see in the context of the contractor rules for Texas sales and use tax purposes has to do with whether a contract should be viewed as a lump-sum or separated contract. The difference can have...

According to an August 19th letter from Senate Finance Committee member Ron Wyden to SEC Chair Paul Akins, there is an ongoing Department of Justice and IRS criminal investigation regarding the sale of “alleged tax...

The recently formed 15th Court of Appeals, created by the Texas Legislature in 2023, has issued what appears to be its first decision involving a tax-related lawsuit and the Texas Comptroller. See Cao v....

When I first started my career as a tax controversy attorney one of the sacrosanct rules was that a Tax Court petition must be filed within 90 days of the date of the IRS Notice of Deficiency (NOD). If a petition...