Federal Tax Procedure

In Alain, L.L.L.P. v. Commissioner, ___ F.4th ___ (5th Cir. 8/12/26), CA5 here; GS [to come], the Court on panel rehearing (also denying en banc rehearing), stuck to its guns and rejected the Tax Court and IRS interpretation of the limited partner exc...

I have posted my Federal Tax Procedure Book to SSRN, see

I have published to SSRN my Federal Tax Procedure Book Student and Practitioner Editions. For information on the SSRN links to download see the page to the right titled “Federal Tax Procedure Book (2026 Editions) (8/4/26)” here.

I am trying to wrap up the 2026 Editions of my Federal Tax Procedure Book but the ongoing drama by DOJ’s $2.77 billion Anti-Weaponization Fund and Trump and related party tax immunity does not permit an easy stopping point. But I have to stop and have just concluded all that will be in the 2026 Editions that I hope to publish later this week. I thought I would post the discus...

Recently, Senator John Kennedy (yeah, the folksy speaking one) and a Trump judicial nominee discussed conservative dogma in Constitutional interpretation (dogma that also plays out in statutory interpretation because the Constitution is just a super-statute). The discussion starts here