Monthly Archives: April 2026

The Tax Court’s recent decision in Arbor Vita Corporation d.b.a. Hemediagnostics v. Commissioner, 166 T.C. No. 5 (Mar. 16, 2026), is a sharp reminder that a timely petition is not enough if your corporate client lacks capacity under state law. For California entities in particular, the case shows that a later “revivor” will not rescue a petition once the IRS has a statute of limitations defense in hand.

The setup: a timely CDP petition by a dead‑in‑the‑water corporation

Arbor Vita is a California biotech corporation that ended up with unpaid federal unemployment tax and penalty liabilities. The IRS filed a Notice of Federal Tax Lien and issued a Collection Due Process (CDP) notice under section 6320. Arbor Vita did what we advise clients to do: it requested a CDP hearing and, after Appeals issued a Notice of Determination on March 6, 2025, it filed a petition with the Tax Court on April 3, 2025—within the 30‑day period in section 6330(d)(1).

There was one fatal problem: California had already suspended Arbor Vita’s corporate powers on July 1, 2024 for state noncompliance, and that suspension remained in place throughout the entire 30‑day filing window. The corporation did not obtain a Certificate of Revivor until September 17, 2025, long after day 30.

The IRS moved to dismiss for lack of jurisdiction, arguing the petition was filed by an entity that lacked capacity to sue.

Capacity, not just timeliness: how Rule 60(c) and California law collide

Tax Court Rule 60(c) tells us that a corporation’s capacity to litigate is determined “by the law under which it was organized,” which, here, is California. Under California law, a suspended corporation “may not prosecute or defend an action” in court until it is revived. That disability is more than a technical defect; it goes to the corporation’s legal existence as a litigant.

Judge Landy held that Arbor Vita lacked the “requisite corporate capacity” when it filed its petition and when the 30‑day CDP period expired. Because capacity is a prerequisite to the court’s ability to entertain the case, the petition was a nullity from the outset.

This is a key practice point: Boechler made the CDP deadline non‑jurisdictional and subject to equitable tolling, but it did not change the need for a valid, capacity‑bearing petitioner. You can have a petition that is timely but still incurable if the filer itself had no legal capacity.

Why California revivor couldn’t save the day

Arbor Vita argued that California’s revivor statute, which generally provides that revival restores the corporation’s powers “as if” they had never been suspended, should relate back and validate the petition. California courts do sometimes treat revivor as retroactively curing a suspension for procedural defects.

The Tax Court was not persuaded. Looking to California authority, including Ninth Circuit precedent in Community Electric Service v. National Electrical Contractors Ass’n, the court emphasized a crucial limitation: revivor cannot be applied in a way that strips an opposing party of an accrued statute of limitations defense.

By the time Arbor Vita obtained its Certificate of Revivor, the 30‑day CDP filing period had long expired and the IRS had a fully vested limitations defense. Allowing revivor to “relate back” in this situation would erase that defense, contrary to California’s own statutory scheme and case law. The court also rejected Arbor Vita’s attempt to analogize to California cases treating notices of appeal more forgivingly on revival, noting that those decisions likewise do not authorize undermining an accrued limitations defense.

Bottom line: state law relation‑back doctrine for revivor stops where the government’s limitations defense begins.

Equitable tolling after Boechler: a limit emerges

Post‑Boechler, many taxpayers have looked to equitable tolling as the safety net for CDP petitions. The Tax Court itself has recognized equitable tolling in other contexts, including Belagio Fine Jewelry, Inc. v. Commissioner, 164 T.C. No. 7 (2025), which held the 90‑day section 7436 deadline is tollable in principle.

Arbor Vita tried to use equitable tolling as a backstop, arguing that its suspension should count as an extraordinary circumstance justifying relief. Judge Landy drew an important distinction: equitable tolling is about extending a limitations period when a party, despite diligence, could not file on time. Here, the petition was filed on time; the defect was that the entity doing the filing lacked capacity at that moment.

Because there was no “late filing” to excuse, there was no limitations period to toll. Equitable tolling could not be used to paper over a capacity problem built into state law. That framing matters for future cases: capacity defects sit outside the Boechler clock.

Practice takeaways for tax professionals

For those of us representing corporations in IRS disputes, Arbor Vita is less about exotic doctrine and more about risk management and checklists.

Here are concrete takeaways:

·         Verify good standing before you file. For any corporate or LLC petitioner, confirm its status with the state of organization (and often the state of principal place of business) before drafting the petition. In California, a quick FTB or Secretary of State check can prevent a jurisdictional disaster.

·         Treat suspended status as a red light, not a yellow one. If the client is suspended, get the revivor completed and documented before filing in Tax Court. Filing “to protect the deadline” while suspended may leave you with a petition the court cannot recognize.

·         Don’t over‑rely on revivor’s relation‑back. State law may allow revival to cure some litigation acts during suspension, but not where doing so would deprive the IRS of an already accrued limitations defense. Arbor Vita shows that CDP and similar short‑window actions fall squarely in that danger zone.

·         Separate timeliness analysis from capacity analysis. After Boechler and Belagio, more deadlines are arguably subject to equitable tolling. That does not relax the separate requirement that the petitioner must exist, have capacity, and meet Rule 60(c) at the time of filing.

·         Update engagement letters and internal procedures. Consider adding explicit language about the client’s responsibility to maintain good standing and authorizing you to verify status. On the internal side, build a “capacity check” into your Tax Court filing workflow.

Example: A California S‑corp with a looming 90‑day deficiency deadline and a quiet FTB suspension for missed state returns. Under Arbor Vita, a petition filed on day 89 while suspended is at serious risk, even if the corporation scrambles to revive a month later. The safer path is to prioritize revivor immediately; if revival truly cannot be completed in time, you may need to consider alternative forums or collection strategies rather than assume a defective Tax Court petition can be fixed after the fact.

Have a Tax Problem?

     Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Sources:

1.       https://www.currentfederaltaxdevelopments.com/blog/2026/3/16/corporate-capacity-state-law-revivor-and-the-limits-of-equitable-tolling-an-analysis-of-arbor-vita-corporation-v-commissioner                

2.      https://irstaxtrouble.com/can-corporate-suspension-foreclose-u-s-tax-court-review/  

3.      https://news.bloombergtax.com/daily-tax-report/biotechs-tax-court-petition-fails-due-to-suspended-status 

4.      http://www.smbiz.com/sbtc26.html

5.       https://kpmg.com/kpmg-us/content/dam/kpmg/taxnewsflash/pdf/2026/04/26081.pdf

6.      https://jamanetwork.com/journals/jamaoncology/fullarticle/2705607

7.       https://www.currentfederaltaxdevelopments.com/blog/2026/3/16/corporate-capacity-state-law-revivor-and-the-limits-of-equitable-tolling-an-analysis-of-arbor-vita-corporation-v-commissioner                

8.      https://news.bloombergtax.com/daily-tax-report/biotechs-tax-court-petition-fails-due-to-suspended-status   

9.      https://www.jibudocs.com/public/summaries/b0e4ad4d-c667-080d-44a5-2dc7ee1b0389      

10.   https://www.law360.com/tax-authority/articles/2453637/tax-court-tosses-biotech-co-s-case-over-corporate-status

11.    https://irstaxtrouble.com/can-corporate-suspension-foreclose-u-s-tax-court-review/     

12.   https://www.jdsupra.com/legalnews/a-corporation-s-loss-of-capacity-and-5171697/      

13.   https://supreme.justia.com/cases/federal/us/596/20-1472/   

14.   https://www.currentfederaltaxdevelopments.com/blog/2025/4/15/navigating-the-90-day-deadline-for-employment-tax-redeterminations-the-belagio-fine-jewelry-inc-case-and-equitable-tolling 

15.    https://www.thetaxadviser.com/issues/2025/oct/equitable-tolling-does-not-apply-to-excuse-late-filing-of-petition/

16.   https://www.taxpayeradvocate.irs.gov/wp-content/uploads/2024/12/ARC24_PurpleBook_07_StrengthTPR_45.pdf 

17.    https://www.flclaw.net/suspended-ca-corporations-cannot-file-tax-court-petitions/

18.   https://lacba.org/?pg=lacba-news&blAction=showEntry&blogEntry=98562

19.   https://www.linkedin.com/posts/ben-white-8186525_why-so-sirius-fifth-circuit-rejects-functional-activity-7449857278138060800-Muuz

20.  https://ustaxcourt.gov/files/documents/162_TC_243-260.pdf

21.   https://taxaid.com/criminal-tax-law/tax-court-denies-equitable-tolling-to-firm-that-the-supreme-court-allowed-equitable-tolling/

Read more at: Tax Times blog

On April 13, 2026, the IRS and Treasury released proposed regulations under new Internal Revenue Code section 4475, explaining how a new 1% federal excise tax will apply to many cash transfers from the United States to recipients in foreign countries. Although these rules are still proposed, the underlying tax is scheduled to take effect for transfers made after December 31, 2025.

The basics: what is the new remittance tax?

Section 4475 was enacted as part of the “One Big Beautiful Bill Act” and imposes a 1% excise tax on certain remittance transfers from the U.S. to foreign countries. In plain English, this is an extra 1% federal tax that can apply when you send money abroad through a money transfer business or similar service.

Key points:

·         The tax is 1% of the amount of the taxable remittance transfer.

·         It applies to transfers made after December 31, 2025.

·         The sender is legally liable for the tax, but the remittance transfer provider must generally collect it at the time of the transfer.

When does the tax apply?

The proposed regulations make clear that not every international transfer is taxed.

The 1% tax generally applies when:

·         The money is sent from the United States to a recipient in a foreign country.

·         The sender pays the provider using cash, a money order, a cashier’s check, or a similar physical instrument.

The tax does not generally apply to:

·         Transfers funded directly from a bank account (for example, an ACH or wire from your U.S. checking account).

·         Transfers funded by U.S. debit or credit cards, as described in many current summaries of section 4475.

·         Certain transfers from accounts at institutions subject to the Bank Secrecy Act, such as some credit union account withdrawals, which benefit from a specific statutory exemption.

For many families that still rely on cash or money orders to send support abroad, this distinction will matter a great deal: cash at a storefront remittance business may be taxed, while an online transfer funded directly from a U.S. bank account may not.

Who has to collect and pay?

Under the statute and the proposed regulations, the sender owes the tax, but the burden of collection falls on the “remittance transfer provider” (RTP).

·         Providers (think Western Union, MoneyGram, and similar services) must calculate the 1% tax, collect it from the sender, and remit it to the IRS.

·         Providers report the tax on Form 720, Quarterly Federal Excise Tax Return, and make required semimonthly deposits.

·         If the provider fails to collect the tax from the sender, the provider becomes secondarily liable and must pay it itself.

The IRS has already signaled some limited failure‑to‑deposit penalty relief for the first three quarters of 2026 to give providers time to build systems and processes.

Timing, comments, and what’s next

The proposed regulations are open for public comment, with written comments and hearing requests due June 12, 2026. Taxpayers and industry groups can weigh in on definitions, anti‑avoidance rules, and operational issues before Treasury finalizes the regulations.

Despite the “proposed” label, the tax itself is in the Code and scheduled to apply to qualifying remittance transfers after December 31, 2025, with the first deposits due January 29, 2026 and first quarterly Form 720 filings covering the first quarter of 2026.

Practical planning tips

For individual senders:

·         If you routinely send cash abroad using a storefront remittance service, expect to see a new 1% federal tax line added to qualifying transfers in 2026.

·         If possible, consider using bank‑funded or card‑funded transfers that fall outside the cash‑based definition in section 4475, as currently described by IRS guidance and practitioner summaries.

For remittance transfer providers and financial institutions:

·         Inventory your cross‑border products and identify which are funded by cash, money orders, cashier’s checks, or similar instruments.

·         Build functionality to: (1) flag taxable transfers, (2) calculate and collect the 1% from senders, and (3) integrate the data into your Form 720 and deposit processes.

·         Monitor the final regulations and any additional IRS guidance, including potential updates to Form 720 and excise tax deposit rules under 26 CFR part 40.

If you send money abroad or operate in the remittance space, now is the time to understand how these proposed rules work so you are not surprised when the 1% excise tax becomes part of your 2026 reality.

Have a Tax Problem?

     Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Sources:

1.       https://www.federalregister.gov/documents/2026/04/13/2026-07085/excise-tax-on-remittance-transfers  

2.      https://www.federalregister.gov/documents/full_text/xml/2026/04/13/2026-07085.xml     

3.      https://www.govinfo.gov/metadata/granule/FR-2026-04-13/2026-07085/mods.xml

4.      https://kpmg.com/us/en/taxnewsflash/news/2026/04/tnf-proposed-regulations-excise-tax-on-remittance-transfers.html      

5.       https://rsmus.com/insights/tax-alerts/2025/excise-tax-on-cross-border-remittances.html

6.      https://answerconnect.cch.com/topic/f9a96b801db74045962ae1196ad1f4e9/excise-tax-on-remittance-transfers

7.       https://www.irs.gov/newsroom/treasury-irs-issue-proposed-regulations-on-the-new-remittance-transfer-tax-established-under-the-one-big-beautiful-bill     

8.      https://changeflow.com/govping/tax/irs-proposes-rules-for-1-remittance-transfer-tax-2026-04-12     

9.      https://www.ecfr.gov/current/title-26/chapter-I/subchapter-D/part-40

10.   https://www.taxesforexpats.com/articles/expat-tax-rules/remittance-tax.html

11.    https://www.federalregister.gov/public-inspection/2026-07085/excise-tax-on-remittance-transfers

12.   https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202210&RIN=1545-BL98

13.   https://news.bloomberglaw.com/daily-tax-report/irs-issues-proposed-regulations-on-1-percent-excise-tax-on-certain-remittance-transfers

14.   https://www.law.cornell.edu/cfr/text/26/part-40

15.    https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202004&RIN=1545-BO98

16.   https://www.federalregister.gov/documents/2026/04/13/2026-07085/excise-tax-on-remittance-transfers          

17.    https://answerconnect.cch.com/topic/f9a96b801db74045962ae1196ad1f4e9/excise-tax-on-remittance-transfers  

18.   https://kpmg.com/us/en/taxnewsflash/news/2026/04/tnf-proposed-regulations-excise-tax-on-remittance-transfers.html               

19.   https://www.irs.gov/newsroom/treasury-irs-issue-proposed-regulations-on-the-new-remittance-transfer-tax-established-under-the-one-big-beautiful-bill                

20.  https://basswoodcounsel.com/sending-money-abroad-guide-obbba-remittance-transfersexcise-tax/   

21.   https://www.taxesforexpats.com/articles/expat-tax-rules/remittance-tax.html              

22.   https://www.simple720.com/blog/one-big-beautiful-bill-act-section-4475-explained    

23.   https://www.americascreditunions.org/blogs/compliance/what-included-remittance-transfer-tax   

24.  https://uniteller.com/ut-blog/remittance-tax-guide/   

25.   https://news.bloombergtax.com/daily-tax-report/irs-issues-proposed-regulations-on-1-percent-excise-tax-on-certain-remittance-transfers

26.  https://mb.ntd.com/treasury-irs-propose-1-percent-remittance-tax-rules-for-money-sent-to-foreign-countries_1138041.html

27.   https://changeflow.com/govping/tax/irs-proposes-rules-for-1-remittance-transfer-tax-2026-04-12

28.  https://www.ecfr.gov/current/title-26/chapter-I/subchapter-D/part-40

29.  https://www.federalregister.gov/public-inspection/2026-07085/excise-tax-on-remittance-transfers

30.  https://www.irs.gov/newsroom/one-big-beautiful-bill-news

31.   https://www.westernunion.com/blog/en/us-remittance-tax/

32.   https://www.facebook.com/blacktaxpro/posts/excise-tax-on-remittance-transfers-what-providers-need-to-knowstarting-january-1/855388700416195/

Read more at: Tax Times blog

• Are You Tired of Trump 2.0.
• That The Republicans Now Control the House & the Senate.
• Are You Sick of Liberal Democrats Trying to Revise Society.
• Are You Tired of Government Shout Downs or
• Maybe You're A Naturalized U.S. Citizen Or Permanent Resident Who Has Prospered Here, But Would Now Like To Move Back The Old Country For Retirement?

You Might Want to Consider Expatriation?

The Internal Revenue Service said in its notice that the number of people who lost or renounced their U.S. citizenship totaled 1,600 in the third quarter as logged by the U.S. Treasury Department, a 50% increase from the previous quarter.

Included on the list are those who lost U.S. citizenship under Internal Revenue Code Section 877(a) and Section 877A, according to the notice, as well as long-term residents who are treated as losing citizenship under Section 877(e)(2). 

According to CNBC the top reason why Americans abroad want to dump their U.S. citizenship include:

• Nearly 1 in 4 American expatriates say they are “seriously considering” or “planning” to ditch their U.S. citizenship, a survey from Greenback Expat Tax Services finds.  
• About 9 million U.S. citizens are living abroad, the U.S. Department of State estimates.
• More than 4 in 10 who would renounce citizenship say it’s due to the burden of filing U.S. taxes, the Greenback poll shows.

Should I Stay or Should I Go?

Need Advise on Expatriation?

 

Contact the Tax Lawyers at 

Marini & Associates, P.A.   

for a FREE Tax Consultation contact us at:

www.TaxAid.com or www.OVDPLaw.com 
or Toll Free at 888-8TaxAid (888) 882-9243

Read more at: Tax Times blog

The IRS’s long‑running battle with Florida taxpayer Burt Kroner shows how far the government will go to reach assets held in offshore trusts when a large tax bill goes unpaid. In United States v. Kroner et al., 9:25‑cv‑80877 (S.D. Fla., West Palm Beach), the government sued Kroner, family members, and a Bahamian trustee to repatriate foreign trust assets and satisfy a tax liability topping $27–28 million.

The backstory: cash transfers and Bahamian trusts

The Kroner dispute traces back to cash transfers Kroner received from a former British business associate between 2005 and 2007. According to court filings, he received about $25 million in cash, took the position that the transfers were not taxable, and then moved substantial amounts into Bahamian trusts.

Two structures are central to the current enforcement case:

• The Kroner Family Trust 2004, funded with roughly $12.675 million via a series of transfers from 2005–2006.
• The Kroner Family 2007 Trust (often referenced as a separate settlement), funded with another $5 million in 2007.

By 2012, the IRS had assessed approximately $13 million in tax, penalties, and interest related to the transfers, and litigation ensued over deficiency and penalties, including the Eleventh Circuit’s decision in Kroner v. Commissioner on section 6751(b) supervisory approval. While the procedural penalty fight was significant, it did not eliminate the underlying income tax, and the government alleges that, over nearly two decades, Kroner’s unpaid balance has ballooned to around $27–28 million with additions and interest.

The enforcement suit: repatriation and injunctive relief

On July 10, 2025, the United States filed a civil action in the Southern District of Florida, United States v. Kroner et al., seeking to collect the assessed liabilities and reach assets held in the Bahamian trusts. 

The complaint names as defendants:offshorealert+3

• Burt Kroner
• Family members Alyson (Allyson) and William Kroner
• Equity Trust Bahamas Ltd. as trustee of the 2004 and 2007 Bahamian trusts.dockets.justia+2

The government’s theory is straightforward: although the assets sit in foreign trusts under Bahamian law, Mr. Kroner and his family benefit from them and have sufficient control or influence that a U.S. court can order them to take steps to bring assets back to the United States. 

• Enforcement of federal tax liens arising from the assessments.
• Injunctive relief restricting transfers from the Bahamian trusts.
• A repatriation order compelling Kroner to cause sufficient trust assets to be brought into the U.S. to satisfy the IRS’s claim.

Notably, this collection case follows a bankruptcy proceeding in which a Florida bankruptcy court ruled that the Bahamian trusts and their assets were not subject to the automatic stay, clearing the way for separate district court enforcement.

Bahamian law vs. U.S. collection power

A major flashpoint is whether Bahamian law can insulate the trusts from U.S. collection efforts. Kroner’s side has pointed to foreign law constraints and argued that the IRS compromised any secured lien position by filing an unsecured proof of claim in bankruptcy, attempting to undermine the government’s lien‑enforcement posture.

DOJ’s response is that foreign law cannot be used as a shield when a U.S. court has personal jurisdiction over the taxpayer. In March 2026 filings, the government argued that:

• The court can order a U.S. taxpayer–beneficiary to exercise whatever rights and powers he has over foreign trust structures to repatriate assets.
• Personal jurisdiction over the settlor/beneficiary is enough to support repatriation and injunctive relief, even though the court cannot directly command the foreign trustee

This line of argument echoes earlier repatriation and contempt cases, where courts have jailed taxpayers who refused to bring back offshore assets despite having the ability—at least on paper—to direct trustees or otherwise access the funds.

Injunctions, freezes, and a settlement

Early 2026 saw key motion practice over how tightly the Bahamian trusts would be restricted while the case was pending. On one hand, DOJ moved for strong relief, including an offshore asset freeze and repatriation of funds. On the other, the defense argued for access to trust assets for living expenses and contested the scope of any freeze.

Public reports show a middle path:

• In February 2026, the court granted a preliminary injunction limiting transfers from the Bahamian trusts and partially freezing the accounts, while allowing a measured flow of funds to the family.
• DOJ later agreed to drop its broader bid for a full offshore asset freeze as part of a partial deal governing ongoing trust distributions during the litigation.

By April 2026, Bloomberg and other outlets reported that Kroner and the IRS had reached a settlement resolving the dispute over the frozen Bahamian trust funds. Filings indicate that the resolution followed the court’s injunction and negotiations over access to the foreign trust accounts, though detailed terms were not publicly disclosed.

Practical lessons for planners and taxpayers

For tax professionals and planners working with clients who have offshore trusts or are considering them, Kroner offers several practical takeaways:

• Offshore does not mean off‑limits. U.S. courts repeatedly show that they will use personal jurisdiction, the All Writs Act, and federal collection statutes to force repatriation of foreign assets when necessary to satisfy tax or other federal debts.
• Trust “control” is broader than formal titles. Even if a foreign trustee appears independent, a settlor or beneficiary with practical ability to influence distributions or trustee decisions may be treated as capable of bringing assets back, with civil contempt as the enforcement hammer.
• Bankruptcy does not solve offshore exposure. The fact that a bankruptcy court allowed the Bahamian trusts to sit outside the automatic stay did not prevent DOJ from later pursuing the assets through a targeted district court enforcement case.
• Long‑term noncompliance gets very expensive. Kroner’s alleged liability grew from an initial assessment in the low‑teen millions to roughly $27–28 million over time, illustrating how interest and penalties can compound during years of resistance and litigation.news.
• Procedure matters, but it is not everything. The earlier Eleventh Circuit opinion in Kroner v. Commissioner on section 6751(b) limited penalty exposure, yet the core income tax liability survived, and the IRS remained willing to litigate aggressively to collect.legacy.

For advisors, the message is clear: clients cannot rely on foreign trust structures or local secrecy laws to escape U.S. tax enforcement once they are under the jurisdiction of a federal court. The better path is proactive compliance, early engagement with the IRS when issues appear, and careful planning that assumes U.S. courts will look through form to substance in offshore arrangements.

 Have an IRS Tax Problem?

   Contact the Tax Lawyers at

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Sources :

   1.       https://dockets.justia.com/docket/florida/flsdce/9:2025cv80877/693294       

2.      https://www.law360.com/cases/68704c94365c8adb5e1824a0/articles      

3.      https://www.law360.com/tax-authority/articles/2456426/bahamian-law-can-t-shield-trusts-in-28m-tax-suit-doj-says       

4.      https://www.offshorealert.com/usa-v-burt-kroner-et-al-complaint-to-repatriate-assets-28m-tax-liability-bahamas-trusts/         

5.       https://dockets.justia.com/docket/florida/flsdce/9:2025cv80876/693292

6.      https://flabizlaw.org/wp-content/uploads/2026/01/BK-UCC-CLE-Materials-Wealth-Transfers-and-Fraudulent-Transfers-1.29.26.pdf 

7.       https://www.law360.com/tax-authority/articles/2439990/doj-drops-bid-for-offshore-asset-freeze-in-28m-tax-suit 

8.      https://www.law360.com/articles/2439990/doj-drops-bid-for-offshore-asset-freeze-in-28m-tax-suit 

9.      https://plannedgiving.howard.edu/?pageID=134&Cat=4&docID=1008

10.   https://descrybe.ai/case-details/c8240837

11.    https://casetext.com/case/kroner-v-commr-of-internal-revenue?p=1&q=48+F.4th+1272&sort=relevance&type=case

12.   https://www.plainsite.org/courts/florida-southern-district-court/atlantic-specialty-insurance-company-inc-v-okeefe-painter-architects-llc-et-al/366724sf2/

13.   https://www.flsd.uscourts.gov/sites/flsd/files/availablecases/21-CV-81180-RLR.pdf

14.   https://www.taxpayeradvocate.irs.gov/wp-content/uploads/2020/07/ARC18_Volume1_MLI_SignificantCases.pdf

15.    https://www.justice.gov/archive/tax/usaopress/2008/txdv08_080822-01.pdf

Read more at: Tax Times blog