Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 9, 2026 – March 25, 2026. AI controversy developments March 20, 2026: The US Tax Court is considering developing a disciplinary framework for the misuse of artificial intelligence (AI) in litigation following concerns raised by Judge Mark V.
Tax Controversy 360
McDermott’s Real-Time Tax Disputes Insights
Latest from Tax Controversy 360 - Page 2
AI platforms and privilege: Tax departments should be wary about what they share
Today’s artificial intelligence (AI) platforms have shown impressive capabilities that keep evolving. As those capabilities improve, tax departments may be inclined to leverage AI’s analytical power. While this technology has led to incredible efficiencies, we’ve been warning in-house tax departments about which platforms they use and what information they share to avoid waiving privilege or…
Is your ERC claim protected? Keep an eye on litigation deadlines
In February 2026, the Internal Revenue Service (IRS) announced that, as of December 31, 2025, it had closed all non-examined Employee Retention Credit (ERC) claims. This development could compel businesses to pursue litigation to secure their ERC refunds. In its announcement, the IRS also noted that approximately 41,000 claims remain under IRS examination or appeal.…
IRS roundup: March 3 – March 10, 2026
By Kai M. Fenty
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 3, 2026 – March 10, 2026. IRS guidance March 3, 2026: The IRS released Revenue Procedure 2026-15, which provides the inflation-adjusted luxury automobile depreciation limits under Internal Revenue Code (Code) Section 280F for passenger vehicles, including trucks and…
IRS roundup: February 17 – February 27, 2026
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for February 17, 2026 – February 27, 2026. February 17, 2026: The IRS released Revenue Ruling 2026-6, which provides the March 2026 applicable federal rates. February 18, 2026: The IRS released Notice 2026-7, which provides additional interim guidance and updates…
Refund claims gain national attention: COVID-19 disaster period may eliminate underpayment interest and penalties
Taxpayers that paid underpayment interest or failure-to-file or failure-to-pay penalties between January 20, 2020, and July 10, 2023, may have viable refund claims. In some cases, the potential recoveries are substantial, but refund statutes of limitation are running and may expire on a rolling basis. National attention has accelerated around this issue, including a recent…
IRS roundup: February 9 – February 17, 2026
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for February 9, 2026 – February 17, 2026. IRS guidance February 9, 2026: The IRS issued Revenue Procedure 2026-13, providing discount factors for insurance companies to compute Section 846 discounted unpaid losses and recoverable Section 832 discounted estimated salvage for…
New USPS postmark rules may impact tax filings
Effective December 24, 2025, the United States Postal Service (USPS) adopted final rules that revise how postmarks are defined and treated. These changes have important implications for taxpayers who plan to mail their tax returns and rely on postmarks to establish timely filing. Under the new framework, the USPS has clarified and, in some cases,…
IRS roundup: January 21 – February 9, 2026
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for January 21, 2026 – February 9, 2026. January 26, 2026: The IRS released Notice 2026-9, which provides a one-year extension to make certain amendments to individual retirement arrangements (IRAs), simplified employee pension arrangements, and savings incentive match plan for…
IRS roundup: January 13 – January 20, 2026
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for January 13, 2026 – January 20, 2026. January 13, 2026: The IRS released Notice 2026-12, which provides the 24-month average corporate bond segment rates for January 2026, the yield curve and segment rates for single-employer plans, and the 30-year…