Insights
Hindsight is 20/20: JM Assets and the Blow to Tax Certainty
Published on July 17, 2025
5 minute read
As seen in Procedurally Taxing - Tax Notes Federal
In this article, the first of a two-part series, Managing Director Jenni Black examines the Tax Court opinion in JM Assets, and she argues that by determining reg. section 301.6235-1(b)(2)(i) is “invalid,” the court opinion removes quite a bit of certainty for both taxpayers and the government.
Explore the second article of the series as Jenni continues her examination of JM Assets LP, questions whether the Tax Court actually held reg. section 301.6235-1(b)(2) was invalid and discusses the impact the opinion has on tax certainty.
Latest Article Cards

Insights
Published July 16, 2025
Unlocking the Power of Agentforce: Salesforce’s Leap into Autonomous AI
Read More

Insights
Published July 15, 2025
Where Are CRE Leaders Seeking Financing in 2025?
Read More

Insights
Published July 15, 2025
Unlocking Liquidity Through Sales and Lease Back Transactions
Read More