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 July 23, 2025
What the "No Tax on Tips" Provision Means for your Restaurant - and What to Do About It
Read More

Insights
Published July 23, 2025
Artificial Intelligence Tools, Digital Automation, and the Future of the Staffing Industry: A Conversation with BJ Hoffman
Read More

Insights
Published July 22, 2025
From Showroom to Shutdown: Keeping Dealership Sales Rolling Through Disruption
Read More

Insights
Published July 17, 2025
Hindsight is 20/20: JM Assets and the Blow to Tax Certainty
Read More