Edward L. Froelich
Subscribe to Edward L. Froelich's PostsEdward L. Froelich represents domestic and foreign public corporations, privately held companies, partnerships, trusts and individuals across the spectrum of federal tax controversies, including audits, trials and appeals. Ed’s clients include businesses, business owners and investors with operations and interests in the financial services, technology, real estate, healthcare and other industries. Read Edward Froelich's full bio.
Latest tax updates: IRS launches automatic penalty relief program and court invalidates GILTI rule
By Akiva B. Ungar and Edward L. Froelich on Jul 20, 2026
Posted In Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform
Several notable tax developments have recently emerged, including the Internal Revenue Service’s (IRS) new automatic penalty relief program and a taxpayer-favorable court decision that struck down a key global intangible low-taxed income (GILTI) regulation. The US Department of the Treasury and the IRS also finalized guidance on life insurance contract transactions and issued updates affecting...
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Latest tax updates: Section 7508A refund claims, whistleblower award eligibility, and court restrictions on IRS collection
By Kai M. Fenty and Edward L. Froelich on Jul 14, 2026
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, IRS Guidance, Penalties, Significant Court Decision, Tax Reform, Tax Refunds
This roundup covers key Internal Revenue Service (IRS) developments from June 23 to July 2, 2026, including a notable executive nomination, new electronic filing procedures for COVID-19 disaster relief refund claims, and three significant court decisions shaping tax controversy. June 23, 2026: US President Donald Trump nominated Jim Gadwood, a tax controversy partner at Miller...
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Government drops statute of limitations defense in McKesson cost-sharing challenge
By Kai M. Fenty and Edward L. Froelich on Jul 10, 2026
Posted In Court Procedure Matters, Significant Court Decision, Tax Refunds
We previously reported on McKesson Corporation’s motion for summary judgment on the grounds that the US Department of the Treasury’s stock-based compensation cost-sharing regulations under Internal Revenue Code (IRC) § 482 were invalid as exceeding its delegated authority and invalid based on procedural violations of the Administrative Procedure Act. On June 5, 2026, the government...
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IRS roundup: June 10 – June 21, 2026
By Kai M. Fenty and Edward L. Froelich on Jun 23, 2026
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, IRS Guidance, Significant Court Decision, Tax Reform, Trial Courts
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 10, 2026 – June 21, 2026. June 9, 2026: A Treasury Inspector General for Tax Administration (TIGTA) report found that the IRS lost a significant number of experienced employees during the workforce reductions and voluntary departures that occurred...
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IRS roundup: May 18 – May 26, 2026
By Kai M. Fenty and Edward L. Froelich on Jun 3, 2026
Posted In Court Procedure Matters, IRS Appeals, IRS Guidance, Significant Court Decision, Tax Reform, Tax Refunds, Trial Courts
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 18, 2026 – May 26, 2026. May 19, 2026: A Treasury Inspector General for Tax Administration (TIGTA) report warned that the IRS’s efforts to transition to a “zero-paper” processing system faces significant obstacles related to funding, staffing shortages,...
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IRS roundup: May 7 – May 18, 2026
By Kai M. Fenty and Edward L. Froelich on May 22, 2026
Posted In Appellate Courts, Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform, Trial Courts
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 7, 2026 – May 18, 2026. May 13, 2026: The IRS announced a time-limited settlement initiative for eligible conservation easement and historic preservation easement cases, offering taxpayers an opportunity to resolve disputes on terms the agency described as...
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Pilot models at scale: What George v. Commissioner teaches about the research credit
By Akiva B. Ungar, Mike Tenenboym and Edward L. Froelich on May 15, 2026
Posted In Court Procedure Matters, Significant Court Decision, Trial Courts
The US Tax Court’s recent decision in George v. Commissioner, T.C. Memo. 2026-10, addressed the application of the Section 41 research credit to supply qualified research expenses (QREs), focusing on whether chickens used in drug trials can qualify as “supplies.” The case provides useful insight into how courts evaluate technical uncertainty under Section 174 for...
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IRS roundup: April 20 – May 1, 2026
By Kai M. Fenty and Edward L. Froelich on May 7, 2026
Posted In Appellate Courts, Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform, Trial Courts
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 20, 2026 – May 1, 2026. April 23, 2026: The IRS has reportedly begun the process of terminating a lead criminal investigation agent involved in probes of Malta pension structures and Puerto Rico’s Act 60 tax incentives, raising...
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IRS roundup April 1 – April 9, 2026
By Kai M. Fenty and Edward L. Froelich on Apr 13, 2026
Posted In Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform, Trial Courts
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 1, 2026 – April 9, 2026. April 3, 2026: The White House proposed significant budget cuts to the Treasury Inspector General for Tax Administration (TIGTA), reducing its funding by nearly 17% for fiscal year 2027 to the lowest...
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The Employee Retention Credit: Ninth Circuit affirms denial of injunction, but leaves door open on merits
By Akiva B. Ungar and Edward L. Froelich on Mar 27, 2026
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, Significant Court Decision, Trial Courts
Case: ERC Today, LLC v. McInelly, Case No. 25-2642 (9th Cir. Mar. 17, 2026) We previously discussed the US District Court for the District of Arizona’s April 2025 order denying a motion for a preliminary injunction filed by two tax preparation firms challenging the Internal Revenue Services’ (IRS) automated “risking” model for processing Employee Retention...
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