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 Articles
Insights
Published June 02, 2026
Manufacturing and Distribution in 2026: Resilience, Risk, and What Comes Next
Read More
Insights
Published June 01, 2026
Microsoft 2026 Work Trend Index Insights: The AI Shift is Redefining How Work Gets Done
Read More
Insights
Published May 26, 2026
Managing AI Risk with Confidence: A Governance Foundation Built on NIST and COSO
Read More
Insights
Published May 20, 2026
The Hacker’s Playbook and How Internal Audit Rewrites It
Read More


