Tax Court Rejects Due Process Challenge to BBA Audit Regime in Jones Bluff

On March 19, 2026, in Jones Bluff, LLC v. Commissioner, 166 T.C. No. 6 (2026), the Tax Court held that a partnership could not assert due process claims to invalidate an IRS adjustment on behalf of its partners under the Bipartisan Budget Act of 2015 (the “BBA”) regime. The decision does not rule on whether any particular aspect of the BBA is consistent with the Due Process Clause of the U.S. Constitution, but it does provide guidance on how due process claims would be received in the future –... By: Proskauer - Tax Talks