February 2026

Key highlights include updates regarding the Tax Court finds economic substance doctrine must be “relevant” to a transaction, IRS attorney says in email advice that a copy of a tax return provided to the IRS as proof of filing purports to be a valid return, and the Fifth Circuit held limited partner exception applies to any partner that has limited liability under state law, regardless of how active the partner is in the partnership. Additionally, the Court of Federal Claims finds section 7508A COVID-19 disaster relief period ran from January 20, 2020 until July 10, 2023.

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