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 December 29, 2025
Understanding the Benefits of Managed IT Services
Read More
Insights
Published December 23, 2025
Webinar Recap Navigating Tariff Trade and Customs Compliance
Read More
Insights
Published December 22, 2025
Uncharted No More: Fees and Carried Interest in the Independent Sponsor Sector
Read More


