Tax Court Rejects Due Process Challenge to BBA Audit Regime in Jones Bluff | Proskauer - Tax Talks
Case Summary
In Jones Bluff, LLC v. 6 (2026), the Tax Court addressed the issue of whether a partnership could raise due process challenges to IRS adjustments under the Bipartisan Budget Act of 2015 (BBA) audit regime. The court held that the partnership itself could not assert due process claims on behalf of its partners to invalidate such IRS adjustments. While the decision did not definitively rule on the constitutional validity of the BBA provisions themselves, it clarified how due process claims related to the BBA would be treated in future litigation. This ruling provides important procedural guidance for partnerships and their partners facing IRS audits under the BBA framework, emphasizing that due process challenges must be brought by individual partners rather than the partnership entity. The case underscores the limited scope of partnership standing in tax litigation and the continuing evolution of audit procedures under the BBA regime.
Stage
Active litigation
Timeline
1 event
Coverage
1 article
Sources
1
Key Issues
- • Due process rights under the BBA audit regime
- • Partnership standing in tax litigation
- • IRS adjustment challenges
- • Bipartisan Budget Act of 2015
- • Tax Court procedural rulings
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Case Timeline
1 eventTax Court Rejects Due Process Challenge to BBA Audit Regime in Jones Bluff | Proskauer - Tax Talks
In the case of Jones Bluff, LLC v. 6, the Tax Court ruled that a partnership cannot use due process arguments to challenge IRS adjustments made under the Bipartisan Budget Act of 2015 audit rules on behalf of its partners. This means that partnerships are limited in their ability to contest IRS changes through due process claims within this specific audit framework. The ruling clarifies how due process challenges are treated under the BBA regime, signaling that such claims are unlikely to succeed in future cases.