2026-05-02
In April 2026, the Tax Court published 7 opinions, which included a total of 94 pages. Below are graphs for the month showing: (i) the top 15 code sections referenced, (ii) cases cited 5 or more times, (iii) the number of opinions by judge, and (iv) the number of pages by judge.
I am always interested in learning well-established tax principles. Often, court cases will explicitly indicate that a tax principle is well established or well settled. Or the court may concisely state the holding of a prior case in a parenthetical. Below are excerpts from the April 2026 Tax Court cases referring to these types of principles or holdings.
Barrios v. Commr., T.C. Memo. 2026-32. (Urda)
Du Poux v. Commissioner, T.C. Memo. 1994-448 ("[F]ailure to receive tax documents does not excuse taxpayers from the duty to report income.")
Sawyer v. Commr., T.C. Memo. 2026-33. (Copeland)
Rodriguez v. Commissioner, T.C. Memo. 2009-22 ( "[T]he IRS has full authority to prepare [a substitute for return] for anyone who fails to file his own return.")
Simmons v. Commr., T.C. Memo. 2026-34. (Urda)
Marquis v. Commissioner, 49 T.C. 695, 702-03 (1968) ("[The taxpayer's] charitable clients represented a substantial, continuing, integral part of her business. . . . [I]t would stretch credulity to characterize the payments [to them] as 'contributions.'")
Simmons v. Commr., T.C. Memo. 2026-34. (Urda)
May v. Commissioner, T.C. Memo. 1996-135 ("[Taxpayer] did not adequately explain why the payments [to religious organizations] were appropriate or helpful to his [piano] business, or how he expected them to produce commensurate benefits for his business . . . .")
Varian Medical Systems, Inc. v. Commr., 166 T.C. No. 8 (2026). (Toro)
Burnet v. Clark, 287 U.S. 410, 415 (1932) ("A corporation and its stockholders are generally to be treated as separate entities")
Varian Medical Systems, Inc. v. Commr., 166 T.C. No. 8 (2026). (Toro)
Ford Motor Co. v. United States, 908 F.3d 805, 809 (Fed. Cir. 2018) ("Another longstanding legal principle treats parent corporations and their subsidiaries as separate taxable entities.")
In April 2026, the IRS published 7 Announcements, Notices, Revenue Procedures, and Revenue Rulings, which included a total of 42 pages.
In April 2026, the IRS published 81 Written Determinations, which included a total of 479 pages.
