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

atrium glass roof interior modern architecture indoor trees sustainabilityatrium glass roof interior modern architecture indoor trees sustainability

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.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Services

Key contacts

halesheppard@eversheds-sutherland

Hale E. Sheppard

Partner

Atlanta, United States

Latest Insights

  • guides and reports
  • legal updates
  • legal updates
  • legal updates

Latest News

Latest Events

EU-flags-at-the-European-Commission-Berlaymont-building-cropped

guides and reports

October 23, 2026

An abstract image of a building

legal updates

October 21, 2026

Electricity transmission pylons across rural landscape energy infrastructure power lines

legal updates

October 21, 2026

Modern office building glass facade exterior

legal updates

October 21, 2026

© Eversheds Sutherland 2026. All rights reserved. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed or affiliated firms and the members of Eversheds Sutherland (Europe) Limited and Eversheds Sutherland (Africa) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global entity. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client. For further information about these Eversheds Sutherland Entities and Eversheds Sutherlands’ structure please see the Legal Notices page of this website.