You Can’t Always Get What You Want (in Tax Litigation)

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You Can’t Always Get What You Want (in Tax Litigation)

July 27, 2026

United States
United States
United States
TAX NOTES FEDERAL

When the taxpayers and the IRS disagree, litigation often ensues.  Both sides tend to be competitive and convinced that they are correct.  Whoever prevails at trial might not matter, though, if the remedy sought by the victor does not exist.  This happens too often in tax disputes, and it should serve as a warning to those who fail to see the forest for the trees.  This article by Partner Hale Sheppard explores three recent tax cases where the parties, focused on winning smaller points, lost sight of the bigger picture:  They failed to request solutions that the court could grant.

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halesheppard@eversheds-sutherland

Hale E. Sheppard

Partner

Atlanta, United States

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