Tax ControversyOctober 2, 2026
Tax Court Deficiency Procedure Versus Refund Suit Jurisdiction
Taxpayers have two mutually exclusive paths to court, each with its own jurisdictional rules.
6 stories by Rafael Treviño-Garza
Taxpayers have two mutually exclusive paths to court, each with its own jurisdictional rules.
Material participation status determines whether pass-through income faces the 3.8% surtax.
How the IRS lets businesses choose their tax classification on a form.
Four separate tax limits must clear before a pass-through loss reaches your return.
The substantial economic effect test determines which special allocations the IRS will respect.
Service businesses face stricter rules and income thresholds for this permanent tax deduction.