The Cannon Corporation and Subsidiaries ("Cannon") appealed a Tax Court decision that upheld the Commissioner of Internal Revenue’s determination of a tax deficiency for the 2011 tax year. The central issue was whether Cannon, as a designer of energy-efficient buildings, could retroactively report Section 179D deductions for the 2007-2010 tax years on its 2011 tax return as an accounting method change, and whether its equitable estoppel, equitable recoupment, and duty of consistency claims were valid. The Court of Appeals affirmed the Tax Court’s judgment, finding that Cannon could not claim the deductions as an accounting method change and that its equitable claims lacked merit.

Judge Jeremy Kernodle of the US District Court for the Eastern District of Texas has issued a stay of the injunction against enforcement of the Beneficial Ownership Reports required by the Corporate Transparency Act he had previously issued in the case of Smith v. Treasury. He indicates the stay is being issued in light of the Supreme Court’s order in McHenry v. Texas Top Cop Shop, Inc.

The stay order can be downloaded via this link.

This case, Green Valley Investors, LLC v. Commissioner, T.C. Memo. 2025-15, involves a consolidated proceeding of four related cases concerning noncash charitable contribution deductions claimed by four partnerships for tax years 2014 and 2015. The partnerships in these cases are Green Valley Investors, LLC (Green Valley), Big Hill Partners, LLC (Big Hill), Tick Creek Holdings, LLC (Tick Creek), and Vista Hill Investments, LLC (Vista Hill). Bobby A. Branch served as the tax matters partner for each of the partnerships. The partnerships had each claimed charitable contribution deductions for the donation of conservation easements totaling approximately $90 million. The Internal Revenue Service (IRS) disallowed the deductions, asserting that the conservation easement deeds did not comply with the requirements of section 170 of the Internal Revenue Code (IRC), and also assessed accuracy-related penalties.

Here’s a summary of the provisions in each of the four bills that were unanimously approved by the House Ways & Means Committee on February 12, 2025

This revenue procedure, Rev. Proc. 2025-16, provides guidance on depreciation deductions for passenger automobiles placed in service in calendar year 2025, as well as income inclusion amounts for lessees of passenger automobiles with a lease term beginning in 2025. The procedure includes tables that reflect inflation adjustments required by § 280F(d)(7) of the Internal Revenue Code.

The government’s arguments in the Texas Top Cop Shop and Community Associations briefs share many similarities, as both cases involve challenges to the Corporate Transparency Act (CTA) and the government’s defense of its constitutionality. However, there are also some differences in emphasis and approach, likely due to the specific nature of the plaintiffs in each case.

The government’s brief argues for the reversal of the district court’s preliminary injunction against the Corporate Transparency Act (CTA), asserting that the district court erred in its legal conclusions and in granting nationwide relief. The government contends that Congress acted within its enumerated powers when enacting the CTA and that the balance of equities favors the government.

In PLR 202506004 a decedent had left various retirement accounts to a trust which was to transfer first funds to a charity, with any amounts left over to individual beneficiaries via a trustee-to-trustee transfer.  The PLR is looking for rulings on the tax treatment of these transactions.

In Peoplease, LLC v. Commissioner, T.C. Memo. 2025-14, the Tax Court reviewed a determination by the Internal Revenue Service (IRS) Independent Office of Appeals to uphold a proposed levy action against Peoplease, LLC, for unpaid liabilities reported on Form 941, Employer’s Quarterly Federal Tax Return, for the tax period that ended December 31, 2021. The court ultimately granted the IRS’s motion for judgment on the pleadings, finding no abuse of discretion by the Appeals Officer.

The defendants, the United States Department of the Treasury, are requesting a stay of the court’s order granting a preliminary injunction against the enforcement of the Corporate Transparency Act (CTA). The defendants have filed a motion for a stay pending appeal to the Fifth Circuit, arguing that the stay is warranted based on the Supreme Court’s decision to stay a similar injunction in a parallel case, McHenry v. Texas Top Cop Shop.  But the agency is also indicating that changes may come to the CTA reporting requirements before reports would become due if the court grants this motion.

In a legal action concerning the IRS’s handling of Employee Retention Credit (ERC) claims taking place in the U.S. District Court in Arizona, two opposing documents outline significantly different perspectives on the matter. The plaintiffs, Stenson Tamaddon, LLC, and ERC Today, LLC, argue for a preliminary injunction against the IRS, asserting violations of the Administrative Procedure Act (APA) and the Fifth Amendment Due Process Clause. The IRS, in its opposition, contests these claims, defending its procedures and challenging the plaintiffs’ standing and legal arguments.

Chief Counsel Advice 202505027 addresses the validity of extensions to the statute of limitations for partnership adjustments under the Bipartisan Budget Act of 2015 (BBA) audit rules. The memorandum concludes that the extensions in question were invalid because they were not signed by the designated partnership representative (PR) or designated individual (DI) as required by law.

In Clark v. Commissioner, T.C. Memo. 2025-13, the Tax Court addressed whether the taxpayer was liable for self-employment tax and an accuracy-related penalty. The Court resolved both issues in favor of the Commissioner.

In Langlois v. Commissioner, T.C. Memo. 2025-12, the Tax Court addressed a deficiency of $27,820 and an accuracy-related penalty of $5,564 asserted by the IRS against Thomas W. Langlois for the 2015 tax year. The court’s decision hinged on Mr. Langlois’s failure to substantiate deductions for unreimbursed employee business expenses and partnership losses, largely due to inadequate recordkeeping. This case underscores the critical importance of maintaining meticulous records to support tax deductions.

The Fifth Circuit’s recent decision in Balentine v. United States serves as a critical reminder of the "pay first, litigate later" principle that has long governed federal tax refund litigation. This article will delve into the details of the Balentine case, its reliance on the landmark Supreme Court decision Flora v. United States, 362 U.S. 145 (1960), and provide a comprehensive analysis of the issues involved for the benefit of tax professionals.

This private letter ruling (PLR 202505002) addresses the deductibility of medical expenses related to in vitro fertilization (IVF) and gestational surrogacy under Internal Revenue Code Section 213.

In January 2025, Senators Crapo (Republican Chair of the Senate Finance Committee)  and Wyden (Ranking Democrat on the Senate Finance Committee and immediately previous Chair) released a discussion draft of bipartisan legislation (tentatively with a name of the Taxpayer Assistance and Service Act (TAS)) aimed at improving IRS procedures and administration. The proposed legislation is intended to enhance the taxpayer experience by facilitating better communication between the IRS and taxpayers, streamlining tax compliance and dispute processes, and ensuring access to timely expert assistance.

In the case of Carol D. Gomez v. Commissioner, Docket No. 3339-24S, the Tax Court addressed a taxpayer’s request for relief from joint and several liability for a tax deficiency arising from a joint return. The Court’s decision, rendered orally by Special Trial Judge Diana L. Leyden on December 11, 2024, provides a detailed analysis of the facts, the taxpayer’s arguments, and the relevant legal authorities. The Court ultimately concluded that Ms. Gomez was not entitled to relief under any of the provisions of I.R.C. § 6015.

This case, Leo v. Commissioner, T.C. Memo. 2025-9, involves a dispute over the valuation of a property donated to charity and the resulting tax implications for the petitioners, Karl W. and Fay L. Leo. The central issue is the fair market value of the Bankhead Property, consisting of buildings and 136.4 acres of land in Union County, Mississippi, as of December 31, 2013. The Leos claimed a charitable contribution deduction based on a valuation of $15,800,000, while the Commissioner of Internal Revenue asserted a value of $4,050,000. The Tax Court sided with the Commissioner, finding the value to be $4,050,000 and upheld the deficiencies and penalties assessed against the Leos.

In Tooke v. Commissioner, 164 T.C. No. 2 (2025), the Tax Court adjudicated a case concerning a taxpayer’s challenge to the IRS Independent Office of Appeals’ structure and staffing. The petitioner, Charlton C. Tooke III, sought review of a Notice of Determination that sustained a federal tax lien and proposed levy action, which stemmed from his unpaid federal income tax liabilities for the years 2012 through 2017. The case is notable for its examination of the Appointments Clause, the separation of powers doctrine, and the specific roles within the IRS Independent Office of Appeals.