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Amanda H Nussbaum on Muck Rack

Amanda H Nussbaum

As seen in: Law360, JD Supra, The National Law Review, Lexology, Mondaq, Westlaw Today, LexBlog, Open Legal Blog Archive
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Articles

In Liberty Global, the Tenth Circuit Leaves Taxpayers with an Opinion with Unresolved Questions

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By Amanda H Nussbaum, Martin Hamilton, Richard Corn
| Westlaw Today Verified
On April 21, 2026, in Liberty Global, Inc. v. United States, the Tenth Circuit held that the economic substance doctrine was "relevant" and applied to deny Liberty Global, Inc. a $2.4 billion deduction and imposed a 40%...
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Update: Federal Rulings Ease COVID‑Era Interest, Penalty and Filing Burdens

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By Laura L. Gavioli, Abraham Gutwein, Amanda H Nussbaum
| Open Legal Blog Archive
Update: The National Taxpayer Advocate has published a blog post urging taxpayers to evaluate whether they have claims for refund based on the recent Abdo and Kwong decisions. Importantly, the Taxpayer Advocate suggests that the argument for penalty and interest relief based on the COVID pandemic disaster declarations is substantial enough to warrant providing for additional time for claims thereunder to be filed.
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Tax Court Rejects Due Process Challenge to BBA Audit Regime in Jones Bluff

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By Amanda H Nussbaum, David Miller, Richard Corn
| Open Legal Blog Archive
On March 19, 2026, in Jones Bluff, LLC v. Commissioner, 166 T.C. No. 6 (2026), the Tax Court held that a partnership could not assert due process claims to invalidate an IRS adjustment on behalf of its partners under the Bipartisan Budget Act of 2015 (the “BBA”) regime.
Open in Who Shared View Duplicates (3) Issue with article?
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