But-For Causation and the Essential Business Hurdle: Analyzing the Summary Judgment in RAAM Construction — Current Federal Tax Developments
RAAM Construction Inc v. United States of America, Case No. 2:25-cv-04681-SPG-AJR, 2026 WL 18391 (C.D. Cal. June 23, 2026). The Employee Retention Credit (ERC) codified under Internal Revenue Code Section 3134 remains a significant source of controversy, audits, and high-stakes federal litigation.
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