Final word on tariffs, assessment limits and the reach of the tax code.
September 17, 2026 at 9:54 AM PDT
A September 17 ruling said Ukraine’s tax authority cannot begin a documentary unscheduled desk audit before properly serving the taxpayer with the audit order and notice.
By declining to hear Murrin v. Commissioner, the justices let stand a Third Circuit ruling that the IRS can assess tax at any time on a fraudulent return, even when only the preparer intended to cheat.
The February 20 ruling found the emergency-powers law never authorized import tariffs, voiding two rounds of duties and setting off refund claims that Penn Wharton estimates could reach $175 billion.
Justices on both sides pressed the administration on emergency tariff powers. If the tariffs fall, importers' refunds may hinge on customs deadlines that start running long before a ruling.