Gray Proctor was quoted in a Law360 article titled “4 Ways Justices’ Jarkesy Ruling Could Affect Tax Controversy.” The article addresses the ways that the 2024 landmark case Jarkesy v. SEC will reshape tax disputes in the near future, as lower courts interpret it. The key outcome of Jarkesy is
Megan L. Brackney, Victor Suthammanont, Gray Proctor, and Andy Weiner co-wrote an article for Tax Notes titled “Can [Tax] Promoter Penalties be ‘Excessive Fines’ Under the Eighth Amendment?” The article is the third in a series considering the constitutional problems with the tax shelter promoter penalties of IRC § 6700.
Gray Proctor was quoted in a recent Tax Notes article titled “Court Finds Promoter Penalties Don’t Deprive Right to Jury Trial.” The article addresses HDH Group v. United States as the next landmark case pursuant to the 2024 decision SEC v. Jarkesy (603 U.S. 109) concerning taxpayers’ rights to a
Gray Proctor was quoted in a recent Tax Notes article titled “Trade Court Overturns Trump Tariffs; Order Stayed on Appeal.” The article addresses the pending U.S. Supreme Court review of the U.S. Court of Appeals for the Federal Circuit’ 7-4 ruling in the consolidated cases of V.O.S. Selections v. United
Kostelanetz attorneys Megan L. Brackney, Victor Suthammanont, and Gray Proctor co-wrote an article for Tax Notes Procedurally Taxing blog titled “Does Due Process Require More Than Refund Jurisdiction Over Tax Promoter Penalties?” In the article, they discuss tax shelter promoter penalties under §6700 and how the imposition of promoter penalties
Kostelanetz counsel Gray Proctor will present during the International Fiscal Association (IFA) North America Trilateral Current Developments Webinar on July 23, 2025. The webinar runs from 4 p.m. to 6 p.m. Eastern time. Continuing education credits are offered for attendance. The webinar will address tax-related developments in North American trade
Law360 quoted Gray Proctor in a recent article reviewing the top federal tax cases of 2025 so far. Gray discusses Commissioner v. Zuch, a case in which a divorced woman challenged the nearly $28,000 in taxes the IRS insisted she owed. The IRS satisfied the amounts due from tax refunds
Gray Proctor was quoted in a series of Tax Notes articles covering the emerging split of authority on which court has jurisdiction to hear challenges to presidential authority to levy tariffs under the International Emergency Economic Powers Act (“IEEPA”). On May 28, 2025, the U.S. Court of International Trade (CIT)
Kostelanetz counsel Gray Proctor wrote an article for the Florida Bar Journal titled “Twelve Angry Taxpayers: Why the Constitution Might Guarantee a Jury Trial for Accuracy and Fraud Penalties in Tax Cases after SEC v. Jarkesy.” Gray examines the U.S. Supreme Court’s June 2024 decision in SEC v. Jarkesy, et al.,
Kostelanetz attorneys Andrew Weiner, Todd Welty, and Gray Proctor have filed two friend of the court (amicus) briefs on behalf of the Center for Taxpayer Rights in cases in which taxpayers are seeking jury trials to challenge civil tax fraud penalties issued by the IRS or the U.S. Tax Court.
