This week we look at: Denham Outlines Its Criticisms of the Tax Court’s Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners Understanding New Clean Electricity Credit Termination Rules I...
Aug 16, 2025•1 hr 38 min
This week we look at: Urgent Guidance Requested on Section 174A Domestic Research and Experimental Expenditures Post-Referral Authority in Tax Litigation—IRS Lacked Authority to Approve ERC Refund Closer This Time, But Still Not Quite There—Another Microcaptive Loss for the Taxpayers Proposed Amendments to IRC Section 132 Fringe Benefit Rules: Switching to NAICS Understanding Passthrough Losses and Bankruptcy in Field Attorney Advice 20253101F Proactive Engagement with the Office of Professional...
Aug 10, 2025•1 hr 36 min
This week we look at: Filing Season Forecast to Start in Mid-February in the Coming Season Settlement Proceeds Found to Be Taxable and Taxpayer Stuck With Late-Filing Penalties IRS Issues Relief for Certain Issues Related to Partnership Investments and the Corporate Alternative Minimum Tax Corporate Mergers and the Same Taxpayer Rule for Interest Netting What Is an Educational Organization for Unrelated Business Income Tax (UBIT) Purposes? Another Microcaptive Arrangement Falls Under Court Chall...
Aug 02, 2025•1 hr 38 min
This week we look at: Understanding 2026 ACA Adjustments Substantiating Noncash Charitable Contributions Filing Proper Refund Claims 2026 Employer Shared Responsibility Payments (ESRP) Changes to IRS LB&I Tax Examinations
Jul 26, 2025•1 hr 2 min
This week we look at: Conservation Easement Deductions: A Critical Review of Rock Cliff Reserve, LLC Portability Election Pitfalls: A Deep Dive into Estate of Rowland and DSUE Requirements Understanding Equitable Tolling in Tax Court: Insights from Boechler, P.C. v. Commissioner A Critical Review of Veribest Vesta, LLC v. Commissioner of Internal Revenue: Implications for Conservation Easement Valuations Understanding Withholding and Reporting for Uncashed Retirement Plan Distribution Checks: A ...
Jul 19, 2025•1 hr 48 min
This week we look at: Recent Developments: Interpreting the Johnson Amendment in Tax-Exempt Status Litigation An Examination of Contract Formation in Tax Court Settlement: Insights from Arden Row Assets, LLC Jurisdictional Imperatives in Tax Court: A Case Study on Timeliness and Last Known Address Expanding Horizons: Potential Changes to Disaster Tax Relief Under the Filing Relief for Natural Disasters Act...
Jul 14, 2025•1 hr 41 min
This week we look at: Bad Debt Deduction and Accuracy-Related Penalties: Key Takeaways from Anaheim Arena Management, LLC v Commissioner FBAR Compliance and the CPA’s Due Diligence Under Circular 230 Dissecting Partnership Audit Limitations: Insights from JM Assets, LP v. Commissioner Decoding Penalty Assessments: A Deep Dive into Moxon Corporation v. Commissioner Tax Court Scrutiny: Upholding Civil Fraud Penalties in Beleiu v. Commissioner...
Jul 07, 2025•1 hr 18 min
This week we look at: Court Upholds IRS’s Employee Retention Credit Guidance Taxpayer Files in US District Court as the IRS’s Failure to Act on its Appeal Was Causing the Statute of Limitations to Run Out IRS Updates K-2 and K-3 Filing Requirements FAQ, Expands Exceptions to Filing Taxpayer Advocate Releases Fiscal Year 2026 Objectives Report to Congress Trust Fund Recovery Penalties: A Case Study on "Responsible Person" and "Willfulness" Under 26 U.S.C. § 6672...
Jun 30, 2025•1 hr 31 min
This week we look at: Schwartz v. Commissioner : The Critical Role of Estimated Tax Compliance in Collection Due Process Determinations Cano v. Commissioner : Validity of Notice of Deficiency and Address Errors Key Differences Between House and Senate Tax Provisions in Reconciliation Process to Date
Jun 22, 2025•1 hr 9 min
This week we look at: Understanding Automatic Accounting Method Changes-Revenue Procedure 2025-23 Accounting Method Changes in Conmac Investments, Inc. Conservation Easements in Glade Creek Partners, LLC Tax Treaty Exemptions in Kramarenko v. Commissioner Tax Refund Litigation & Variance Doctrine in Shleifer v. U.S. Tax Court Jurisdiction in Commissioner v. Zuch Digital Asset Reporting & Withholding in Notice 2025-33...
Jun 13, 2025•1 hr 39 min
This week we look at: Navigating Corporate Alternative Minimum Tax (CAMT) Conservation Easement Valuation & Penalties: A Warning from Tax Court Collection Due Process (CDP) & Offers in Compromise (OICs): Lessons from Tax Court Accuracy-Related Penalties: Navigating Negligence and Insufficient Professional Reliance Understanding Treasury’s Request for Information on Modernizing Federal Payments Worthlessness vs. Discharge: A Ninth Circuit Examination of Bad Debt Deductions Concurrent with...
Jun 08, 2025•1 hr 50 min
This week we look at: Self-Employment Tax for Limited Partners ( Soroban II ) Presidential Tariffs Under IEEPA (USCIT Decision & Federal Circuit Stay) Massachusetts Source Income (Welch Case Petition) Foreign Gift Penalties (Huang Case)
May 30, 2025•1 hr 20 min
This week we look at: IRS Reduces Estate Tax Closing Letter Fee Tax Court Scope of Review in Passport Cases Marital Deduction for Bequests to Trust “Reasonable Cause” in Late-Filing Penalty Cases “No Tax on Tips Act” (S.129) Passes Senate Transfer Pricing in Facebook, Inc. & Subsidiaries v. Commissioner Navigating New York’s Convenience Rule: Insights from Matter of Zelinsky
May 26, 2025•1 hr 31 min
This week we look at: Deductibility of IVF and Gestational Surrogacy Costs Fraudulent Tax Claims & 28 U.S.C. § 2514 Tax Collection Suits & Statute of Limitations in United States v. Ragen Moving Expense Deduction - Civilian Department of Defense Contractor Eligibility Tax Court Jurisdiction - The 90-Day Deadline for Deficiency Petitions
May 09, 2025•1 hr 19 min
This week we look at: Navigating the Overlap: Civil Tax Assessments and Criminal Restitution Orders Navigating Innocent Spouse Relief: A Look at Salvi v. Commissioner Supreme Court Weighs Tax Court Jurisdiction in Levy Disputes After Tax Payment: A Deep Dive into Commissioner v. Zuch Navigating ERISA Prohibited Transaction Claims: Insights from Cunningham v. Cornell University
Apr 25, 2025•1 hr 7 min
This week we look at: Navigating the 90-Day Deadline for Employment Tax Redeterminations: The Belagio Fine Jewelry, Inc. Case and Equitable Tolling GWA, LLC v. Commissioner: Substance Over Form and the Nuances of Tax Elections for Disregarded Entities Notice 2025-23: Treasury and IRS Signal Withdrawal of Basis Shifting TOI Regulations and Related Penalties Hobby Loss and Failure to File: A Deep Dive into Himmel v. Commissioner
Apr 18, 2025•1 hr 6 min
This week we look at: Massachusetts Source Income and the Sale of Stock by a Nonresident Navigating the Valuation Landscape: Insights from Pierce v. Commissioner Personal Liability for Corporate Sales and Use Tax: An Analysis of Matter of the Appeal of B. Wageman Navigating the IRS’s ERC Claim Processing Moratorium and "Risking" Procedures Jurisdictional Prerequisites in Tax Refund Suits: A Case Study of Estate of Robert F. Armitage, Deceased v. The United States Dependency Claims and Child Tax ...
Apr 16, 2025•1 hr 42 min
This week we look at: Ranch Springs, LLC v. Commissioner : A Case Study in the Valuation of Conservation Easements and the Pitfalls of Aggressive Tax Planning The Duty of Consistency Prevails: A Case Study in Innocent Spouse Relief and Subsequent Asset Claims Navigating the Murky Waters of Investment Tax Credits and Passive Activity Rules: A Deep Dive into Strieby v. Commissioner
Apr 06, 2025•47 min
This week we look at: Tax Court Finds Taxpayer Failed to Provide a Qualified Appraisal, No Charitable Deduction Allowed Estate Found Liable for $2 Million FBAR Penalty That Applied to the Decedent Taxpayers Filing Court Challenges to Attempt to Obtain Employee Retention Tax Credits Fourth Circuit Overturns Trial Court’s Grant of Summary Judgment to the Government, Finding True Issue of Fact Exists Regarding Whether Statute Remained Open IRS Memorandum Discusses When a Taxpayer Can Claim a Deduct...
Mar 16, 2025•1 hr 30 min
This week we look at: Treasury and the Corporate Transparency Act (BOI Reporting) Martino v. Commissioner: Alimony Deduction Case Estate of Kalikow v. Commissioner: Estate Tax & Settlement Payments Appeal of A. Markowski: California Source Income for Nonresidents CF Headquarters Corporation v. Commissioner: Taxability of Grants United States v. Gora: IRS Levy Enforcement
Mar 09, 2025•1 hr 13 min
This week we look at: FinCEN Announcement on BOI Reporting Penalties Tax Court Case: Alan Hamel and Estate of Suzanne Hamel v. Commissioner IRS “Dirty Dozen” Tax Scams for 2025 IRS Adds Tax Documents to Online Accounts Ways and Means Committee Passes Disaster Relief Bills House and Senate Budget Resolutions
Mar 02, 2025•1 hr 15 min
This week we look at: Second Circuit Rules on Section 179D Deductions and Accounting Method Change IRS Guidance on ACA Notice Posting Court Case on CPA Negligence and Trust Return Penalties BOI Reporting Requirement Updates
Feb 23, 2025•59 min
This week we look at: Deductibility of Losses: Weston v. Commissioner Conservation Easements: Green Valley Investors LLC Automobile Depreciation and Lease Inclusion S Corporation Inadvertent Termination Relief Corporate Transparency Act (CTA) - Government Briefs House Ways & Means Committee Tax Bills
Feb 16, 2025•1 hr 11 min
This week we look at: IRS issues letter ruling on IRA left to trust A taxpayer mistakenly believes the IRS had conceded that his income was not subject to self-employment tax, but it hadn’t The Tax Court denies a taxpayer’s deductions and claimed partnership losses due to incredibly disorganized and inadequate records Taxpayer runs afoul of the “pay first, litigate later” rule when attempting to sue the IRS for a refund in US District Court in response to an assessment A taxpayer’s unprocessed c...
Feb 08, 2025•1 hr 15 min
This week we look at: Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on Return IRS Finds Most Expenses Related to Taxpayers’ In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213 Taxpayer Denied Innocent Spouse Relief in Tax Court Bench Opinion Tax Court Finds No Issue With the Appeals Office Structure and Staffing Failure to Provide Proof of Filing of Returns Fatal to Taxpayer’s Attempt at Obtaining Rel...
Feb 02, 2025•1 hr 17 min
This week we look at: Funds Taken By Sheriff Were a Valid Loan and Not Income from Embezzlement Tax Court Allows a Reduced Deduction for a Conservation Easement CCA Discusses Issues with Activities of a Private Foundation with Regard to Self-Dealing, Attempted Correction and Jeopardizing Investments IRS Email Discusses Agency’s (Lack of) Obligation to Process Amended Tax Returns Supreme Court Reverses Fifth Circuit Merits Panel, Again Removes Emergency Injunction Against Enforcement of the CTA B...
Jan 26, 2025•1 hr 13 min
This week we look at: IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 property Proposed regulations on catch-up contributions added by the SECURE 2.0 Act Proposed regulations on the automatic enrollment provisions of IRC §414A US Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process case IRS issues final regulations on resolution of tax controversies by the IRS Independent Of...
Jan 19, 2025•1 hr 3 min
This week we look at: IRS Grants Tax Relief to California Wildfire Victims National Taxpayer Advocate’s Report to Congress and Legislative Recommendations Released Third US District Court Issues BOI Reporting Injunction Tax Court Finds a Building Was Not a Certified Historic Structure as Defined by §170(h) Taxpayer Denied Refund as Court Found the Taxpayer Had Taken the Position That Its Reporting Was an Error Rather Than a Method of Accounting Seventh Circuit Upholds Imposition of Fraud Penalty...
Jan 12, 2025•1 hr 21 min
This week we look at: IRS gives relief for specific identification of digital asset basis for certain taxpayers for 2025 only Department of Justice asks the U.S. Supreme Court to Stay the Latest Corporate Transparency Act Injunction IRS no longer to dispute requirement to comply with APA to add listed transactions after the enactment AJCA in 2024 Tax Court rules that merely being in a registered historic area does not make a building a certified historic structure Tax Court finds taxpayer owes t...
Jan 05, 2025•54 min
This week we look at: Automatic accounting method changes related to §174 extended to years beginning in 2024 BOI report - hectic week, but ultimately no resolution yet for initial report due date 2025 mileage rates published by the IRS IRS finalizes regulations on supervisory approval of penalties IRS proposes revisions to Circular 230
Dec 22, 2024•55 min
