Tax Controversy Update — September 2026
Three decisions from this month that change how audits and Tax Court petitions should be handled.
- [Case] v. Commissioner, T.C. Memo. 2026-__Late petition; equitable tolling not available
- [Case] v. Commissioner, 167 T.C. No. __Stipulated facts binding despite later-discovered records
- United States v. [Name] (9th Cir. 2026)Summons enforcement; scope of Powell challenge
Part 1 — Two Tax Court decisions on the 90-day deadline and stipulations
15 minRead the transcript of Part 1
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Part 2 — A Ninth Circuit ruling on IRS summons enforcement, and what to do differently
15 minRead the transcript of Part 2
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Learning objectives
- State the current rule on late Tax Court petitions
- Explain when a stipulation can and cannot be withdrawn
- Identify the grounds still available to resist a summons
Presented by Thomas Ogden, Esq., Certified Specialist in Taxation Law, State Bar of California. Self-study activity, Law Offices of Thomas Ogden, MCLE provider no. 19437. Structured to meet CBA Regulations §§ 88.1–88.2 for self-study CE.
About the presenter
Thomas Ogden is a Certified Specialist in Appellate Law and in Taxation Law, certified by the State Bar of California Board of Legal Specialization, with more than 22 years in practice. He served as a Tax Law Advisory Commissioner to the State Bar of California's Board of Legal Specialization. His tax practice is controversy work: IRS and Franchise Tax Board examinations, Appeals, the Office of Tax Appeals, refund litigation, and the U.S. Tax Court, together with criminal tax defense and cross-border disputes. Much of his work comes by referral from CPAs and enrolled agents who want counsel involved before a civil matter becomes something else. He is also a solicitor (currently non-practising) in England and Wales and in Ireland.
Practice sites: appellate practice · tax controversy practice · Email: thomas@ogden.law
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