Overview
On January 1, 2024, Law360 quoted partner, Lawrence Hill in an article titled “Federal Tax Cases To Watch In 2024.” The article discusses some of the top federal cases that tax professionals will be keeping a close eye on in 2024. The fates of unrealized income under the US Constitution and the IRS’ rulemaking authority under Chevron deference are popular tax topics in cases pending before the US Supreme Court.
Larry, co-chair of the firm's tax controversy practice, commented on the US Supreme Court case of Moore v US: “A broad ruling from the Supreme Court favoring a realization requirement under the 16th Amendment could ‘change the landscape of how income is taxed’ and compel more lawsuits from taxpayers.” He said: “We will see a plethora of litigation challenging various provisions of the tax code,” which could clog up the courts for years. Larry was a co-author of the American Tax Policy Institute’s amicus brief to the Supreme Court in Moore.
