Generally, the IRS has three years to select an income tax return for audit. But if the taxpayer never files an income tax return, the three-year statute of limitations period never starts, providing the agency with unlimited...
Category: Blog
This is the second in a series of refund litigation blog posts. In this post, I focus on requirements that must be satisfied before a taxpayer can file a refund lawsuit. These initial requirements are more than just...
One of the most important questions a taxpayer must necessarily ask itself when performing work on real property is whether the work is an improvement to real property. The rules that apply to real property improvements for...
An Introduction to Tax Refund Litigation
April 10, 2025
When a federal tax issue is not able to be resolved with the IRS, a taxpayer may choose to pursue that issue in court. The vast majority of tax cases are pursued in the United States Tax Court (“Tax Court”). One common...
The Texas Supreme Court Denies Government Exemption to Independent Contractor but Finds “Oddity” in Texas Comptroller Rule
April 1, 2025
In a recently issued decision, the Texas Supreme Court provided a holding on two important matters applicable to exemptions from tax. See GEO Grp., Inc. v. Hegar, No. 23-0149, 2025 WL 852414 (Tex. Mar. 14, 2025). The...