2026-06-05
In May 2026, the Tax Court published 9 opinions, which included a total of 137 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 May 2026 Tax Court cases referring to these types of principles or holdings.
Lee v. Commr., T.C. Memo. 2026-43. (Siegel)
We have repeatedly held that work demands-even extreme ones-do not constitute reasonable cause for purposes of section 6651(a)(1). Dustin v. Commissioner, 53 T.C. 491, 507 (1969), aff'd, 467 F.2d 47 (9th Cir. 1972).
Li v. Commr., T.C. Memo. 2026-42. (Marshall)
DiLeo v. Commissioner, 96 T.C. 858, 885 (1991) ("A taxpayer is collaterally estopped from denying civil tax fraud . . . when convicted for criminal tax evasion under section 7201 for the same taxable year.")
Shryock v. Commr., T.C. Memo. 2026-44. (Arbeit)
Nis Fam. Tr. v. Commissioner, 115 T.C. 523, 538-42 (2000) (holding that, where taxpayers failed to assign "justiciable error" to any of Commissioner's determinations, taxpayers were deemed to concede all deficiency adjustments)
In May 2026, the IRS published 9 Announcements, Notices, Revenue Procedures, and Revenue Rulings, which included a total of 90 pages.
In May 2026, the IRS published 62 Written Determinations, which included a total of 315 pages.
