The recent decision by the United States Court of Appeals for the Third Circuit in Stephanie Murrin v. Commissioner of Internal Revenue, No. 24-2037 (3d Cir. August 18, 2025), delivers a crucial interpretation of Internal Revenue Code (I.R.C.) § 6501(c)(1) that impacts how tax professionals advise clients regarding statutes of limitations, at least in the Third Circuit. This ruling clarifies that the exception allowing the Internal Revenue Service (IRS) to assess tax "at any time" for a false or fraudulent return with intent to evade tax does not require the taxpayer’s personal intent. Instead, the intent of a third party, such as a tax preparer, is sufficient to trigger the indefinite assessment period.

This article examines the recent Tax Court Memorandum decision in Corri A. Feige v. Commissioner of Internal Revenue, T.C. Memo. 2025-88, a case that provides critical insights for tax professionals regarding the income inclusion of property transferred in connection with services, particularly when its receipt is disputed by the taxpayer. The Court’s analysis touches upon the applicability of Section 83, the concept of a "substantial risk of forfeiture," and the nuanced burden of proof rules for both income deficiencies and various additions to tax.

The Internal Revenue Service (IRS) and the Department of the Treasury have issued proposed regulations (REG-108822-25) aimed at modifying information reporting obligations concerning sales or exchanges of certain partnership interests. These proposed changes affect partnerships and seek to alleviate existing compliance burdens by refining the timing of certain reporting requirements for Section 751(a) exchanges.

Superior Pediatric Care, Inc., a for-profit corporation specializing in speech, occupational, and physical therapy services primarily for school children in the Northern District of Texas, has filed an original complaint in the United States District Court for the Northern District of Texas against the United States of America. This complaint seeks a refund of an employee retention credit (ERC), along with interest and reasonable costs and attorneys’ fees, asserting that its properly filed claims have remained unpaid by the Internal Revenue Service (IRS). The case highlights significant concerns among taxpayers and tax professionals regarding the processing delays of ERC claims by the Service.

The Internal Revenue Service (IRS) recently issued Notice 2025-42, providing critical guidance on the "beginning of construction" (BoC) requirements for applicable wind and solar facilities. This notice is a direct response to the termination provisions for clean electricity production credits (§ 45Y) and clean electricity investment credits (§ 48E) introduced by the One, Big, Beautiful Bill Act (OBBBA), Public Law 119-21, and the directives of Executive Order 14315. This article will detail the scope of this ruling, the IRS’s interpretation and application of the law, and the key conclusions affecting tax professionals advising clients in the clean energy sector.

Tax professionals frequently grapple with the intricacies of statutory deadlines, particularly when challenging Internal Revenue Service (IRS) determinations. A recent decision by the United States Court of Appeals for the Second Circuit in Buller v. Commissioner, No. 24-1557 (2d Cir. 2025), has provided crucial clarity regarding the nature of the filing deadline under I.R.C. § 6213(a) for petitions to the U.S. Tax Court. This decision represents a significant shift from previous understandings and has direct implications for how practitioners advise clients facing deficiency notices.

This article provides an in-depth analysis of the Second Circuit’s decision in New Jersey v. Bessent; Village of Scarsdale v. IRS, a significant case heard during the August Term, 2024, and decided on August 13, 2025. The ruling addresses the interplay between state-level tax credit programs designed to circumvent the federal cap on state and local tax (SALT) deductions and the federal charitable contribution deduction under 26 U.S.C. § 170.

As tax professionals, understanding the nuances of partnership taxation, particularly in distressed asset transactions, is crucial. The recent affirmations in PICCIRC, LLC and PIMLICO, LLC v. Commissioner provide critical insights into how courts scrutinize structured transactions and apply anti-abuse doctrines. This article will dissect the United States Tax Court’s original holding and the subsequent affirmance by the Second Circuit Court of Appeals, highlighting key legal interpretations and their practical implications.

The core of the dispute revolves around the application of the limited-partner exception found in 26 U.S.C. § 1402(a)(13) and 42 U.S.C. § 411(a)(12). This exception generally excludes the distributive share of income or loss of a limited partner from net earnings from self-employment, with a specific carveout for "guaranteed payments . . . for services actually rendered". Denham contends that the Tax Court erred by distorting the meaning of "limited partner" through the imposition of a "functional analysis test" and by inappropriately allowing this partner-level determination to occur in a partnership-level proceeding under the TEFRA regime.

The Internal Revenue Service (IRS) recently issued a significant announcement, IR-2025-82, on August 7, 2025, detailing its phased implementation strategy for the One Big Beautiful Bill Act (OBBBA). This news release provides crucial clarity for tax professionals regarding individual information returns and federal income tax withholding for Tax Year (TY) 2025, while also offering a glimpse into forthcoming changes for TY 2026.

The Internal Revenue Service’s Office of Professional Responsibility (OPR) recently issued an OPR Alert, "Fessing Up Can Be in Your Own Best Interests: Self-Reporting of Practitioner Misconduct," on August 6, 2025. This communication offers crucial insights for Certified Public Accountants (CPAs) and Enrolled Agents (EAs) who practice before the IRS, emphasizing the framework of Circular 230 and the potential advantages of proactive self-reporting of misconduct. As tax professionals, understanding these dynamics is paramount to maintaining our privilege of practice and managing potential disciplinary actions effectively.

Field Attorney Advice (FAA) 20253101F, released on August 1, 2025, addresses two critical issues concerning a net operating loss (NOL) carryback claimed by individual taxpayers who are shareholders of an S corporation undergoing Chapter 7 bankruptcy. This memorandum provides valuable insight into the application of S corporation passthrough rules and the implications of corporate bankruptcy on shareholder tax attributes.

The Department of the Treasury and the Internal Revenue Service (IRS) have issued proposed regulations (REG-132805-17) concerning the determination of an employer’s line of business for purposes of applying the exclusion from gross income for no-additional-cost services and qualified employee discounts under Internal Revenue Code (IRC) Section 132. These proposed regulations are intended to update the business classification system used for these fringe benefits to better reflect current economic activity and reduce administrative burden.

The United States Tax Court recently rendered a significant decision in CFM Insurance, Inc. v. Commissioner, T.C. Memo. 2025-83, a case that adds another layer to the complex landscape of microcaptive insurance arrangements. This article provides a comprehensive overview of the case, from its foundational facts to the Tax Court’s nuanced legal analysis and ultimate conclusions.

The recent decision in JPM Restaurant, LLC v. United States, case No. 1:24-cv-00357, from the United States District Court for the Eastern District of Tennessee, offers important insights for tax professionals navigating Employee Retention Credit (ERC) claims that evolve into litigation. This case highlights critical jurisdictional boundaries regarding tax liability compromises once a matter is referred to the Department of Justice (DOJ).

The American Institute of CPAs (AICPA) has formally requested immediate guidance from the Department of the Treasury and the Internal Revenue Service (IRS) regarding Section 174A of the Internal Revenue Code (IRC), which pertains to domestic research and experimental expenditures (domestic research costs). This urgent appeal, addressed to the Honorable Kenneth J. Kies, Assistant Secretary of the Treasury, Tax Policy, highlights critical issues facing eligible small business taxpayers as they finalize their 2024 federal income tax returns.

The recent decision by the United States Court of Appeals for the Eleventh Circuit in Fannie Wright v. Commissioner of Internal Revenue, No. 24-10563, offers important insights into innocent spouse relief and the application of constitutional law in tax disputes. This article details the factual background, the taxpayer’s request for relief, and the Eleventh Circuit’s rigorous analysis of the law, its application to the facts, and the conclusions reached.

The United States Tax Court recently issued T.C. Memo. 2025-81, Kadau v. Commissioner, a ruling for navigating the complexities of microcaptive insurance arrangements. This case, involving Curtis K. Kadau and Surface Engineering & Alloy Co., Inc. (an S corporation of which Mr. Kadau was the sole shareholder), delves into the deductibility of expenses for purported insurance coverage provided through affiliated captive insurance companies, Risk & Asset Protection Services, Ltd. (Risk & Asset) and RMC Property & Casualty, Ltd. (RMC Property). The Internal Revenue Service (IRS) challenged the arrangement, asserting that it did not constitute actual insurance, thus disallowing deductions and imposing accuracy-related penalties.

Understanding the intricate nuances of tax exemptions for nonprofit organizations is crucial for those involved with tax exempt clients. A recent decision from the United States Court of Appeals for the Eighth Circuit, Mayo Clinic v. United States (Case No. 23-2246), provides significant clarity, particularly concerning the definition of an "educational organization" under Internal Revenue Code (IRC) § 170(b)(1)(A)(ii) and its implications for unrelated business income tax (UBIT) exemptions. This article delves into the factual background, the taxpayer’s request for relief, the court’s detailed legal analysis, and its application to Mayo Clinic’s operations, culminating in the court’s conclusions.

The United States Court of Appeals for the Fourth Circuit recently addressed a critical issue for corporate tax professionals regarding the application of the interest netting provision under 26 U.S.C. § 6621(d) following a corporate merger. This case, Bank of America Corporation v. United States (CA4, Case No. 23-2319) provides essential clarity on the interpretation of the “same taxpayer” requirement for pre-merger underpayments and overpayments.