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Fifth Circuit Rejects Tax Court’s “Functional Analysis” Test in Sirius Solutions​

On Friday, January 16, 2026, the U.S. Court of Appeals for the Fifth Circuit issued a landmark decision that fundamentally disrupts the IRS’s recent campaign to limit the § 1402(a)(13) self-employment tax exception. In Sirius Solutions L.L.L.P. v. Commissioner, No. 24-60240, slip op. (5th Cir. Jan. 16, 2026), the Fifth Circuit vacated the Tax Court’s ruling …