By: Mario de Castro, Jordan Halle, Michael March, Harris Cornell, Curtis Paul, and Matt Razzano On May 22,2025, the House of Representatives passed H.R. 1-119th Congress (2025-2026), titled as the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses soon to sunset provisions of the...

Appealing an Internal Revenue Service Examination begins long before a taxpayer considers the United States Tax Court; it is a continuum that starts with an IRS audit, proceeds through the administrative Appeals Office, and, if necessary, culminates in litigation. The audit itself is generally initiated when the Service believes a...