Section Newsletters

Articles From Sandra D. Mertens

Tax Court Takes a Strict Stance on Procedural Deadlines Under the BBA Partnership Audit Rules By Sandra D. Mertens & Grace Symington Federal Taxation, November 2025 Recent Tax Court decisions, including JM Assets and Bayou Serpent, demonstrate strict enforcement of procedural deadlines. This strict adherence reinforces the importance of diligence and punctuality, safeguarding the integrity of the judicial process by emphasizing the necessity of complying with procedural requirements. 
2025 Illinois Tax Amnesty Programs Offer Opportunities for Penalty and Interest Relief to Taxpayers By Sandra D. Mertens & Grace Symington Federal Taxation, October 2025 Familiarize yourself with the 2 amnesty programs that will take effect in the fall of 2025 as a direct result of House Bill 2755, signed by Governor Pritker on June 16, 2025. 
Recent Changes to the IRS Office of Appeals By Sandra D. Mertens & Grace Symington Federal Taxation, October 2025 The Internal Revenue Service (IRS) Independent Office of Appeals is launching two initiatives aimed at increasing transparency and fairness to taxpayers: (1) a Post Appeals Mediation pilot program, and (2) making Appeals Case Memos available to share with taxpayers.
Tax Consequences of Settlement Agreements: Lessons From Mennemeyer v. Commissioner By Sandra D. Mertens Federal Taxation, September 2025 A case summary of the U.S. Tax Court matter, Adrienne Mennemeyer v. Commissioner of Internal Revenue, T.C. Memo 2025-80, and lessons learned on taxation of settlements. 
Roundup of Recent IRS Penalty Abatement Caselaw By Sandra D. Mertens Federal Taxation, June 2024 Summaries of several recent court decisions with interesting penalty abatement results.
U.S. Supreme Court to Decide Whether 2017 Mandatory Repatriation Tax Is Constitutional and Satisfies Due Process in Moore v. United States By Sandra D. Mertens Federal Taxation, March 2024 The Tax Cuts and Jobs Act of 2017 significantly changed portions of the U.S. tax code, including adding the Mandatory Repatriation Tax, which imposes tax on certain U.S. shareholders of foreign corporations.
The Corporate Transparency Act Will Be a Big Deal for Small Businesses By Sandra D. Mertens Federal Taxation, October 2023 On January 1, 2021, Congress enacted the Corporate Transparency Act, intended to prevent criminals from using companies for money laundering, corruption, tax evasion, drug trafficking, fraud, and other crimes.

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