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On May 19, 2026, the NAM filed an amicus brief asking the Tax Court to prevent the IRS from taxing non-income that has no impact on the tax liability of partnerships. In this case, the Tax Court will consider the validity of the imputed underpayment rules implemented by the IRS pursuant to the 2015 Bipartisan Budget Act for the first time. Our amicus brief urges the court to interpret the regulations reasonably and find that government’s power to tax is strictly limited to income-producing items that impact a corporate taxpayer’s tax liability. Broad expansion of this power violates the Constitution and poses a major threat to private enterprise.