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....
Equitable Tolling Opens the Tax Court Door: The Impact of Oquendo v. Commissioner
August 29, 2025
By Joel N. Crouch, Blog
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...
Employee Retention Credit (ERC) Examinations Surge
August 28, 2025
The Internal Revenue Service has intensified its examination efforts related to Employee Retention Credit (ERC) filings, subjecting claims across the spectrum to heightened review and analysis. Current statistics reveal...
Silver Moss Properties, LLC v. Commissioner: A Tax Court Showdown Over Conservation Easements and the Right to Jury Trial
August 27, 2025
By Joel N. Crouch, Blog
The world of syndicated conservation easements (SCEs) has been a hotbed of litigation in recent years, with the IRS aggressively challenging transactions it considers abusive tax shelters. One recent case, Silver Moss...
Is the Issue of Fraudulent Conduct by the Return Preparer and the Tax Assessment Statute of Limitations Headed to the U.S. Supreme Court?
August 20, 2025
By Joel N. Crouch, Blog
In a blog post last year, I discussed the Tax Court’s decision in Murrin v. Commissioner, T.C. Memo 2024-10. In Murrin, the Tax Court again held that indefinite statute of limitations for tax assessment...