Case Updates
Tenth Circuit denies petition for rehearing en banc, with Judges Hartz, Tymkovich, and Eid dissenting
August 17, 2026
U.S. Chamber files coalition amicus brief urging Tenth Circuit to grant rehearing and encourage predictable and certain application of tax laws by preserving the economic substance doctrine’s threshold relevance inquiry
June 12, 2026
U.S. Chamber Coalition Amicus Brief
Lauren Willard Zehmer, Kevin Otero, Abby Wright, and Jesse Boretsky of Covington & Burling LLP served as outside counsel.
The Chamber previously filed a coalition amicus brief in this case.