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 March 11, 2026
What Importers Need to Know About IEEPA Tariff Refunds: Protecting Your Rights and Maximizing Recovery
Read More
Insights
Published March 11, 2026
Building a Resilient Local Supply Chain in Connecticut
Read More
Insights
Published March 11, 2026
Speed Up Billing and Improve Revenue Clarity with a Unified CRM and ERP
Read More
Insights
Published March 06, 2026
The Effects of Economic Uncertainty on Deal Making and Exit Plans
Read More


