The United States Tax Court, in James D. Sullivan v. Commissioner of Internal Revenue, T.C. Memo. 2025-92, recently outlined procedural requirements for taxpayers seeking relief from IRS collection actions. This memorandum opinion highlights the importance of timely response to a Notice of Deficiency and the necessity of presenting concrete collection alternatives during a Collection Due Process (CDP) hearing. This case serves as a crucial reminder of the procedural hurdles and the specific legal standards applied by the Court in collection cases.

The recent Tax Court memorandum decision in Lisa Marie Walsh v. Commissioner, T.C. Memo. 2025-91 (filed August 26, 2025), offers significant insights into the application of Section 6015 relief from joint and several liability, particularly concerning the doctrines of res judicata and the various factors considered for equitable relief. This article details the factual background, the taxpayer’s request, the court’s legal analysis, and the ultimate conclusions, providing a technical overview for tax professionals.

The third time was not a charm for the IRS and the Tax Court regarding the question of whether the 90-day deadline to file a Tax Court petition to dispute a Notice of Deficiency is a jurisdictional requirement. The United States Court of Appeals for the Sixth Circuit recently issued a significant decision in Naysha Y. Oquendo v. Commissioner of Internal Revenue, reversing the Tax Court’s dismissal of a petition for redetermination due to untimely filing.

As tax professionals, staying abreast of procedural changes from the Internal Revenue Service (IRS) is paramount to ensuring client compliance and avoiding unnecessary complications. In an email issued by Spidell Publishing on August 22, Spidell noted that the IRS has recently confirmed significant revisions to certain mailing addresses for tax payments in recently published IRS Publication 3891, a development that requires immediate attention from all practitioners. These changes affect a variety of federal tax forms submitted with payments, particularly Forms 1040-ES and 941, and carry implications for tax software updates and client communication.

The Internal Revenue Service (IRS) has issued FAQs (FS-2025-05, Aug. 21, 2025) providing initial guidance on modifications to various energy-related tax provisions under Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). These FAQs are intended to offer general information to taxpayers and tax professionals expeditiously. While these FAQs have not been published in the Internal Revenue Bulletin and thus will not be relied upon by the IRS to resolve cases, taxpayers who reasonably and in good faith rely on them will not be subject to certain penalties, such as negligence or other accuracy-related penalties, to the extent such reliance results in an underpayment of tax.

These modifications specifically impact sections 25C, 25D, 25E, 30C, 30D, 45L, 45W, and 179D of the Internal Revenue Code. Future guidance is anticipated on other provisions affected by OBBBA.

The United States Tax Court, in Silver Moss Properties, LLC v. Commissioner, 165 T.C. No. 3 (2025), recently addressed a critical question for tax professionals: whether the Seventh Amendment to the U.S. Constitution guarantees a right to a jury trial for civil fraud penalties under Internal Revenue Code (I.R.C.) Section 6663(a) in a Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) partnership-level proceeding. The court unequivocally held that it retains the authority to adjudicate such penalties without a jury.

The Internal Revenue Service (IRS) has issued a draft version of the 2026 Form W-2, offering insights into the future reporting requirements for employers concerning the qualified tips deduction under IRC §224 and the qualified overtime deduction under IRC §225. Additionally, the draft references a new IRS form, presumably intended for the reporting of these and potentially other items deductible under §63.

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.