This article discusses the case of United States v. Charles S. Brown, et al., Case No. C24-5021, a decision from the United States District Court for the Western District of Washington at Tacoma, offering key insights for tax practitioners dealing with clients who face both civil and criminal tax consequences arising from the same underlying actions. The court’s analysis clarifies the distinct nature of civil tax liabilities and criminal restitution orders, particularly concerning assessment and the statute of limitations on collection.

This article analyzes the recent Tax Court Memorandum decision in Mark P. Himmel and Deborah W. Himmel v. Commissioner of Internal Revenue, T.C. Memo. 2025-35, which provides valuable insights for tax practitioners navigating the complexities of hobby loss rules under Internal Revenue Code (IRC) § 183 and penalties for failure to timely file under IRC § 6651(a)(1).

This article discusses Notice 2025-23, issued by the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS), which announces the intention to remove § 1.6011-18 of the Income Tax Regulations (26 CFR part 1), also known as the Basis Shifting Transaction of Interest (TOI) Regulations. This notice also provides immediate relief from certain penalties associated with these regulations and withdraws Notice 2024-54. Understanding the implications of this notice is crucial for tax practitioners advising clients involved in partnership-related party basis adjustment transactions.

This article delves into the recent United States Tax Court Memorandum decision in GWA, LLC v. Commissioner, T.C. Memo. 2025-34, a case with significant implications for tax practitioners advising partnerships and their partners on complex financial transactions, accounting method changes, and the validity of tax elections made by disregarded entities.

This article analyzes the recent United States Tax Court decision in Belagio Fine Jewelry, Inc. v. Commissioner, 164 T.C. No. 7 (2025), which addresses the crucial issue of equitable tolling of the 90-day deadline for filing a petition for redetermination of employment status under Internal Revenue Code (I.R.C.) § 7436. Understanding the court’s reasoning is essential for tax practitioners advising clients facing employment tax controversies.

This article addresses the significant impact of H.J. Res. 25, a joint resolution passed by Congress and signed into law by President Trump on April 10, 2025. This measure utilizes the Congressional Review Act (CRA) to disapprove and repeal the Internal Revenue Service (IRS) regulations outlined in Treasury Decision (T.D.) 10021, which were aimed at imposing information reporting requirements on certain participants within the decentralized finance (DeFi) sector of the digital asset industry. For tax practitioners, understanding the nuances of this repeal and the content of the now-defunct regulations is crucial for advising clients operating in or interacting with the digital asset space.

This article analyzes Internal Revenue Service (IRS) Notice 2025-24, which provides limited relief from penalties under section 6707A(a) and section 6707(a) of the Internal Revenue Code (Code) for participants and material advisors involved in certain micro-captive reportable transactions. This relief is specifically targeted towards those who failed to file timely disclosure statements related to transactions identified as listed transactions or transactions of interest after the initial filing of tax returns or the point at which an advisor became a material advisor. Understanding the scope and limitations of this notice is crucial for tax practitioners advising clients involved in micro-captive arrangements.

This article provides an overview of the recently released Rev. Rul. 2025-9, which details the updated Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charge for valuing noncommercial flights on employer-provided aircraft under Section 61 of the Internal Revenue Code (IRC). This guidance is crucial for tax practitioners advising clients on the taxation of fringe benefits.

This article provides a technical analysis of the recent Tax Court Memorandum decision, Hampton v. Commissioner, T.C. Memo. 2025-32, which addressed the application of the public policy doctrine to the disallowance of a loss deduction claimed by a shareholder of an S corporation following the forfeiture of the corporation’s assets. This case offers valuable insights for tax practitioners regarding the limitations on loss deductions when those losses are intertwined with illegal activities.

This article analyzes the recent Tax Court Memorandum decision, Zajac v. Commissioner, T.C. Memo. 2025-33, providing a detailed overview of the case for tax practitioners. The case involves a taxpayer, Joseph J. Zajac, III, who contested the Commissioner of Internal Revenue’s (Respondent) determination of deficiencies and accuracy-related penalties for the taxable years 2007 through 2009.

The case of WT Art Partnership LP v. Commissioner, T.C. Memo. 2025-30, offers significant insights for tax practitioners, particularly those advising clients on charitable contributions of high-value art. This memorandum opinion from the United States Tax Court addresses the intricate requirements for substantiating such donations under § 170 of the Internal Revenue Code (IRC), the application of the reasonable cause exception under § 170(f)(11)(A)(ii)(II), the determination of fair market value (FMV), and the imposition of accuracy-related penalties under § 6662. This article will delve into the facts of the case, the taxpayer’s arguments, the court’s legal analysis, its application of the law, and the resulting conclusions.

This article delves into the Tax Court’s decision in Correll v. Commissioner, T.C. Memo. 2025-31, providing a technical analysis relevant for tax practitioners. The case highlights the crucial requirements for claiming a child as a dependent and the subsequent eligibility for the child tax credit, particularly in situations involving separated or divorced parents.

This article delves into a recent decision by the United States Court of Federal Claims in Estate of Robert F. Armitage, Deceased, Robert H. Armitage and Adam M. Green, Executors v. The United States, No. 24-1687, filed April 7, 2025. This case serves as a critical reminder for tax practitioners regarding the fundamental jurisdictional requirements that taxpayers must satisfy before seeking judicial intervention in tax refund matters. Understanding these prerequisites is paramount in advising clients and ensuring the proper pursuit of refund claims.

This article delves into the recent case of ERC Today LLC, et al. v. John McInelly, et al., No. CV-24-03178-PHX-SMM (D. Ariz. Apr. 7, 2025), providing a detailed analysis relevant to CPAs in tax practice who advise clients on Employee Retention Credit (ERC) claims. The case examines the Internal Revenue Service’s (IRS) moratorium on processing ERC claims and its implementation of a "risk assessment model," ultimately leading to the denial of a preliminary injunction sought by tax preparation firms.

This article examines the Office of Tax Appeals (OTA) decision in the Matter of the Appeal of B. Wageman, offering insights for tax practitioners regarding the imposition of personal liability for a corporation’s unpaid sales and use tax obligations under California law. This case highlights the critical factors considered by the OTA, particularly the element of willful failure to pay under Revenue and Taxation Code (R&TC) section 6829 and California Code of Regulations, title 18, section 1702.5.

In the recent Tax Court Memorandum decision, Pierce v. Commissioner, T.C. Memo. 2025-29, filed April 7, 2025, the court addressed a dispute concerning the fair market value of interests in Mothers Lounge, LLC, a baby products company, for federal gift tax purposes. This case provides valuable insights for tax practitioners, particularly CPAs specializing in tax, into the court’s rigorous analysis of business valuation methodologies, the scrutiny of expert witness testimony, and the application of relevant legal principles in the context of closely held business transfers.

The Massachusetts Appeals Court’s decision in Craig H. Welch & another vs. Commissioner of Revenue, No. 24-P-109 (Mass. App. Ct. April 3, 2025), provides crucial guidance for CPAs navigating the complexities of Massachusetts income tax for nonresidents, particularly concerning the taxation of capital gains from the sale of stock. This article will delve into the facts of the case, the taxpayers’ claim for an abatement, the court’s detailed analysis of the relevant statute and regulations, the application of these legal principles to the specific circumstances, and the ultimate conclusions reached by the court.

The Tax Court recently issued its Memorandum Opinion in Kelly M. Strieby and Jan E. Sharon-Strieby v. Commissioner of Internal Revenue, T.C. Memo. 2025-28, providing valuable insights into the complexities surrounding the claiming of investment tax credits under Section 48 of the Internal Revenue Code (the Code) and the limitations imposed by the passive activity credit rules of Section 469. This case, decided fully stipulated under Tax Court Rule 122, serves as a crucial reminder for tax practitioners of the necessity of thorough due diligence when advising clients on tax-advantaged investments, particularly those promising seemingly effortless tax benefits.

Tax practitioners frequently encounter situations involving innocent spouse relief under Internal Revenue Code (IRC) §§ 66 and 6015. These provisions offer a pathway for taxpayers to avoid liability for their spouse’s tax obligations under specific circumstances. However, a recent case in the United States District Court for the Northern District of Texas, United States of America v. John Dee Stacey, et al., provides a crucial reminder of the duty of consistency and its implications when a taxpayer who has received innocent spouse relief later attempts to claim an interest in assets they previously failed to disclose. This article will delve into the facts, the legal analysis, and the court’s conclusions in this case, offering valuable insights for CPAs in tax practice.

Tax practitioners are frequently tasked with assisting clients in claiming tax refunds. A critical aspect of this process is ensuring strict adherence to the statutory and regulatory requirements governing such claims, particularly the timeliness mandates established under 26 U.S.C. § 6511. The recent case of Hamilton v. United States, Case No. 24-cv-04491-BLF (N.D. Cal. Mar. 26, 2025), serves as a potent reminder of the jurisdictional pitfalls awaiting taxpayers who fail to meet these deadlines and the specific evidentiary burdens required for exceptions like financial disability tolling. This article delves into the details of this case, providing insights relevant to CPAs in tax practice.