News•Apr 14, 2026
Tax Court Rejects Due Process Challenge to BBA Audit Regime in Jones Bluff
The Tax Court in *Jones Bluff, LLC v. Commissioner* ruled that a partnership cannot bring due‑process claims on behalf of its partners under the Bipartisan Budget Act (BBA) audit regime. The decision rests on third‑party standing and ripeness doctrines, noting partners can pursue claims later in refund or collection actions. While the court did not address the BBA’s constitutional validity, it signaled that partnership‑level proceedings are not a viable venue for due‑process challenges. The ruling leaves uncertainty about how partners can effectively protect their rights under the BBA.
