2025-10-13 2026 Tax Year Inflation Numbers Published

This week we look at:

• Updated SIFL Rates for Noncommercial Employer-Provided Flights

• Supervisory Approval, Reasoned Decision Making, and the Limits of APA Review in Tax Court

• Tax Exemption Denial for a Gated Community HOA by the Tax Court

• Cancellation-of-Indebtedness Income Timing and the Variance Doctrine

• IRS Contingency Planning: Operational Impact on Tax Practice and Filing Season Preparedness

• 2026 Inflation Adjustments for Tax Professionals

• Accounting Method Failures and Income Reconstruction

• The Concrete Injury Requirement in ERTC Consultant Litigation

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2025-10-13 Current Federal Tax Developments

2025-09-29 The End of Individual Refund Checks Approaches

This week we look at:

• Hobby Loss Rules: Young v. Commissioner, T.C. Memo. 2025-95

• Drought-Forced Livestock Sales: IRS Notice 2025-52

• Per Diem Rates: IRS Notice 2025-54

• End of Paper Refunds: IR-2025-94 / E.O. 14247

• Syndicated Conservation Easements: Jackson Stone South, LLC v. Commissioner, T.C. Memo. 2025-96

• Constructive Receipt & § 4958: Fumo v. Commissioner, T.C. Memo. 2025-97

• Whistleblower Awards: In re: Sealed Case, CA DC, Case No. 24-1001

• Employee vs. Independent Contractor: Gil v. United States, USDC ED PA

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2025-09-29 Current Federal Tax Developments

2025-09-22 Catch-Up Contribution SECURE 2.0 Regulations Released

This week we look at:

• Final Regulations for Catch-Up Contributions (TD 10033)

• Draft Schedule 1-A (Form 1040) for 2025

• Urgent Warnings of State Revenue Department Phishing Scams

• Tax Court Developments (Blomquist Holdings)

• Proposed Tax Administration Legislation

• New Deduction for Qualified Tips: An Overview of Proposed Treasury Regulation §1.224-1

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2025-09-22 Current Federal Tax Developments

2025-09-15 QBI Deduction, W-2 Wages and Section 280E

This week we look at:

• Court Frowns on Professional’s Use of Randomly Generated Social Security Numbers

• Understanding the “Placed in Service” Rule for Electric Vehicle Credits

• Advisers Found to Owe Treble Damages to Impacted Taxpayers

• W-2 Wages and the Qualified Business Income Deduction Under Section 280E

• Trust Fund Recovery Penalties and Refund Claim Timeliness in Richter v. The United States

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2025-09-15 Current Federal Tax Developments

2025-09-08 IRS Releases Preliminary List of Eligible Qualified TIp Occupations

This week we look at:

• Eleventh Circuit: Gross Valuation Misstatement Penalty in a Conservation Easement Case

• Treasury & IRS: Preliminary Guidance on Tipped Occupations

• Eighth Circuit: Medtronic Transfer Pricing Dispute Remanded Again

• California OTA: Entertainer Found to be a California Resident

• Pitfalls in IRA Bankruptcy Exemptions: Farber v. Feldman

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2025-09-06 Current Federal Tax Developments

2025-09-02 Better Late Than Never R&E Procedural Relief

This week we look at:

• Federal Circuit Ruling Finds Limits on Executive Authority to Impose Tariffs Under IEEPA
• Introduction to OBBBA R&E Expenditure Procedures
• Sixth Circuit Realigns on Tax Court Jurisdiction
• Innocent Spouse Relief: Walsh v. Commissioner Overview
• Taxpayer Precluded from Challenging Liability: Sullivan v. Commissioner
• 60-Day IRA Rollover Waiver in a Fraud Scenario

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2025-09-02 Current Federal Tax Developments

2025-08-25 Stump the LLM

This week we look at:

• Federal Complaint Seeking ERC Refunds: Superior Pediatric Care v. United States

• Proposed Revisions to Partnership Information Reporting for Sales or Exchanges of Interests—Form 8308

• Taxation of Unsolicited Stock Transfers: Analysis of Feige v. Commissioner

• Third-Party Intent and the Indefinite Assessment Period: An Analysis of Murrin v. Commissioner

• The One, Big, Beautiful Bill Act (OBBBA): New Deductions & Energy Credit Modifications

• LLM Limitations in Tax Law: Beyond Memorization

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2025-08-25 Stump the LLM

2025-08-18 State Tax Credit SALT Workaround Regulation Challenge Fails

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 Impact of IRS Notice 2025-42 on Wind and Solar Facilities

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2025-08-18 Current Federal Tax Developments

2025-08-11 IRS Announces No Payroll Changes for 2025

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 Responsibility

• IRS Announces Policy for the One Big Beautiful Bill Act for 2025 Payroll Issues

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2028-08-11 Current Federal Tax Developments

2025-08-04 A Late Tax Season Start Expected

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?

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2028-08-02 Current Federal Tax Developments

2025-07-21 Dealing with Uncashed Retirement Plan Checks

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 Review of Rev. Rul. 2025-15

• Fifth Circuit Affirms Tax Court’s Disallowance of Micro-Captive Insurance Deductions: An Analysis of Swift v. Commissioner

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2025-07-21 Current Federal Tax Developments

2025-07-14 Passage of a Much Shorter Additional Tax Bill

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

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2025-07-14 Current Federal Tax Developments

2025-07-07 Win Some Lose Some on Statutes of Limitations for the IRS

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

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2025-07-07 Current Federal Tax Developments

2025-06-30 ERC Issues Return to Court

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

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• 2025-06-30 Current Federal Tax Developments

2025-06-23 Senate Finance Committee Tax Provision Draft Issued

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

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2025-06-23 Current Federal Tax Developments

2025-06-16 The Case of the Vanishing Levy

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

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2025-06-16 Current Federal Tax Developments

2025-06-09 Worthlessness vs Cancellation of Debt Are Not the Same

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 COD Income

• Navigating the Religious Exemption Landscape: A Deep Dive into Unemployment Compensation Tax

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2025-06-09 Current Federal Tax Developments

2025-06-02 Revisiting Previously Discussed Cases

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)

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2025-06-02 Current Federal Tax Developments

2025-05-26 Second Challenge to Convenience of the Employer Rule

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

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2025-05-26 Current Federal Tax Developments

2025-05-19 Passthroughs and the One Big Beautiful Bill

This week we look at:

• IRC Section 7433 and the Scope of the Collection Waiver of Sovereign Immunity

• The Claim of Right Doctrine Applied to Business Errors

• IRC Section 7433: Reinforcing Collection vs. Assessment Distinction

• Selected issues from The One, Big, Beautiful Bill’s tax provisions

• Proposed Changes to the Section 199A Qualified Business Income Deduction

• Proposed Changes Affecting Passthrough Entities and State PTE Taxes

• Interest Deductions and Penalties in Complex Financial Transactions

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2025-05-19 Current Federal Tax Developments