Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute
Published . Updated .
Covered by 2 outlets: Bloomberg Tax, Bloomberg Law News.
A Ninth Circuit panel Monday questioned whether a tax advisory firm can directly challenge IRS employee retention credit guidance under the Administrative Procedure Act, or whether only denied clients can contest it individually.
Directly affected
- No company is named in this report.
Indirectly affected
- XLF Financial Select Sector SPDR-3.9% 30d
Financial Select Sector SPDR: it holds banks. Linked by “credit” (banks) in this story.
- KRE SPDR S&P Regional Banking ETF-4.4% 30d
SPDR S&P Regional Banking ETF: it holds banks. Linked by “credit” (banks) in this story.
- JPM JPMorgan Chase-5.3% 30d
JPMorgan Chase (national commercial banks): banks' earnings move with lending, deposits and rates. Linked by “credit” (banks) in this story.
- BAC Bank of America-15.0% 30d
Bank of America (national commercial banks): banks' earnings move with lending, deposits and rates. Linked by “credit” (banks) in this story.
- WFC Wells Fargo-7.1% 30d
Wells Fargo (national commercial banks): banks' earnings move with lending, deposits and rates. Linked by “credit” (banks) in this story.
- C Citigroup-11.4% 30d
Citigroup (national commercial banks): banks' earnings move with lending, deposits and rates. Linked by “credit” (banks) in this story.
Price reaction, T-5 to T+3
| Ticker | T-5 | T-3 | T-1 | T0 | T+1 | T+2 | T+3 |
|---|---|---|---|---|---|---|---|
| XLF | -1.49% | +0.21% | base | +0.24% | after close | after close | after close |
| KRE | -4.40% | -2.55% | base | +0.35% | after close | after close | after close |
| JPM | +0.58% | +1.08% | base | +0.76% | after close | after close | after close |
| BAC | -0.32% | +0.51% | base | +0.00% | after close | after close | after close |
| WFC | -0.72% | +0.04% | base | +0.33% | after close | after close | after close |
| C | +0.85% | +2.63% | base | +0.34% | after close | after close | after close |
Closing-price change versus T-1, the last close before the story. T0 to T+3 fill in after each market close. Prices: Alpaca IEX.
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Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute Bloomberg Tax
Source: Bloomberg Tax
Select Sector Spdr Tr (XLF) since this story, compared with the market
| Company | When | Move | Status |
|---|---|---|---|
| Bank Of America (BAC) | that day | 0.00% | final price |
| Bank Of America (BAC) | three days earlier | +0.51% | final price |
| Bank Of America (BAC) | five days earlier | -0.32% | final price |
| Citigroup (C) | that day | +0.34% | final price |
| Citigroup (C) | three days earlier | +2.63% | final price |
| Citigroup (C) | five days earlier | +0.85% | final price |
| Jpmorgan Chase (JPM) | that day | +0.76% | final price |
| Jpmorgan Chase (JPM) | three days earlier | +1.08% | final price |
| Jpmorgan Chase (JPM) | five days earlier | +0.58% | final price |
| Spdr Series Trust (KRE) | that day | +0.35% | final price |
| Spdr Series Trust (KRE) | three days earlier | -2.55% | final price |
| Spdr Series Trust (KRE) | five days earlier | -4.40% | final price |
| Wells Fargo (WFC) | that day | +0.33% | final price |
| Wells Fargo (WFC) | three days earlier | +0.04% | final price |
| Wells Fargo (WFC) | five days earlier | -0.72% | final price |
| Select Sector Spdr Tr (XLF) | that day | +0.24% | final price |
| Select Sector Spdr Tr (XLF) | three days earlier | +0.21% | final price |
| Select Sector Spdr Tr (XLF) | five days earlier | -1.49% | final price |
Congressional trades in the stocks in this story
- Sen. Sheldon Whitehouse sold Jpmorgan Chase (JPM) (held by a spouse), worth $15,001 - $50,000 on 4 Sep 2026. That is 52 days before publication. Filed 1 Oct 2026. View the filing.
- Sen. Sheldon Whitehouse sold Jpmorgan Chase (JPM), worth $15,001 - $50,000 on 4 Sep 2026. That is 52 days before publication. Filed 1 Oct 2026. View the filing.
- Rep. Rohit Khanna bought Jpmorgan Chase (JPM) (held by a spouse), worth $100,001 - $250,000 on 27 Aug 2026. That is 60 days before publication. Filed 4 Sep 2026. View the filing.
- Rep. Rohit Khanna sold Bank Of America (BAC) (held by a spouse), worth $1,001 - $15,000 on 9 Sep 2026. That is 47 days before publication. Filed 7 Oct 2026. View the filing.
- Rep. Laurel Lee sold Bank Of America (BAC) (held by a spouse), worth $50,001 - $100,000 on 24 Aug 2026. That is 63 days before publication. Filed 16 Oct 2026. View the filing.
- Rep. Rohit Khanna bought Wells Fargo (WFC) (held by a spouse), worth $1,001 - $15,000 on 25 Sep 2026. That is 31 days before publication. Filed 7 Oct 2026. View the filing.
- Rep. Rohit Khanna bought Wells Fargo (WFC) (held by a dependent child), worth $15,001 - $50,000 on 17 Sep 2026. That is 39 days before publication. Filed 7 Oct 2026. View the filing.
- Rep. Rohit Khanna bought Wells Fargo (WFC) (held by a dependent child), worth $1,001 - $15,000 on 15 Sep 2026. That is 41 days before publication. Filed 7 Oct 2026. View the filing.
- Rep. Maria Elvira Salazar sold Citigroup (C), worth $1,001 - $15,000 on 24 Sep 2026. That is 32 days before publication. Filed 7 Oct 2026. View the filing.
- Rep. Rohit Khanna bought Citigroup (C) (held by a spouse), worth $1,001 - $15,000 on 4 Sep 2026. That is 52 days before publication. Filed 7 Oct 2026. View the filing.
Public disclosure filings, not a recommendation. The filing link is the source document. News use of these reports still sits under 5 U.S.C. § 13107(c).
Who gains and who loses around Select Sector Spdr Tr (XLF)
Companies tied to this story
- XLF Select Sector Spdr Tr
For “Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute,” Select Sector Spdr Tr (XLF) is linked, with no stored direction, medium confidence. Reason on file: Financial Select Sector SPDR: it holds banks. Linked by “credit” (banks) in this story
- KRE Spdr Series Trust
In “Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute,” Spdr Series Trust (KRE) is linked, with no stored direction, medium confidence. Reason on file: SPDR S&P Regional Banking ETF: it holds banks. Linked by “credit” (banks) in this story
- JPM Jpmorgan Chase
For “Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute,” Jpmorgan Chase (JPM) is linked, with no stored direction, medium confidence. Reason on file: JPMorgan Chase (national commercial banks): banks' earnings move with lending, deposits and rates. Linked by “credit” (banks) in this story
- BAC Bank Of America
For “Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute,” Bank Of America (BAC) is linked, with no stored direction, medium confidence. Reason on file: Bank of America (national commercial banks): banks' earnings move with lending, deposits and rates. Linked by “credit” (banks) in this story
- WFC Wells Fargo
For “Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute,” Wells Fargo (WFC) is linked, with no stored direction, medium confidence. Reason on file: Wells Fargo (national commercial banks): banks' earnings move with lending, deposits and rates. Linked by “credit” (banks) in this story
- C Citigroup
Citigroup (C) is linked, with no stored direction, medium confidence in the 26 Oct 2026 story “Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute.” Reason on file: Citigroup (national commercial banks): banks' earnings move with lending, deposits and rates. Linked by “credit” (banks) in this story
Select Sector Spdr Tr (XLF)
On 26 Oct 2026, “Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute” is the story that connects Select Sector Spdr Tr (XLF) to this story.
Select Sector Spdr Tr (XLF) is on the page because Financial Select Sector SPDR: it holds banks. Linked by “credit” (banks) in this story
Also listed, Spdr Series Trust (KRE): SPDR S&P Regional Banking ETF: it holds banks. Linked by “credit” (banks) in this story
Dates and price levels for Select Sector Spdr Tr (XLF)
JPM traded between 325.12 and 344.37 across 20 sessions. The latest close on file is 331.52. KRE traded between 67.80 and 71.93 across 20 sessions. The latest close on file is 70.61. XLF traded between 52.82 and 56.03 across 20 sessions. The latest close on file is 55.07.
A simple score for Select Sector Spdr Tr (XLF)
54 out of 100
“Judges Eye Jurisdiction in Covid-19 Tax Credit Guidance Dispute” scores 54 out of 100. The score uses 2 sources, and 6 linked companies.