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.
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.
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