Insights

Hindsight is 20/20: JM Assets and the Blow to Tax Certainty

Published on July 17, 2025 5 minute read
Practical ERP Solutions Background

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.

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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.

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