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

2025-05-12 Taxpayer Fails to Qualify for Deduction for DoD Ordered Move

This week we look at:

• Deductibility of IVF and Gestational Surrogacy Costs

• Fraudulent Tax Claims & 28 U.S.C. § 2514

• Tax Collection Suits & Statute of Limitations in United States v. Ragen

• Moving Expense Deduction - Civilian Department of Defense Contractor Eligibility

• Tax Court Jurisdiction - The 90-Day Deadline for Deficiency Petitions

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2025-05-12 Current Federal Tax Developments

2025-05-05 Will We See PL 86-272 Finally Revised?

This week we look at:

• ERC Claims Filed Without Schedule R

• Reasonable Cause for Information Return Penalties: Reliance on Software

• Proposed Expansion of P.L. 86-272 "Solicitation of Orders" Definition

• 2026 Inflation Adjustments for HSAs and Excepted Benefit HRAs

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2025-05-05 Current Federal Tax Developments

2025-04-28 Twice to the Supreme Court

This week we look at:

• Navigating the Overlap: Civil Tax Assessments and Criminal Restitution Orders

• Navigating Innocent Spouse Relief: A Look at Salvi v. Commissioner

• Supreme Court Weighs Tax Court Jurisdiction in Levy Disputes After Tax Payment: A Deep Dive into Commissioner v. Zuch

• Navigating ERISA Prohibited Transaction Claims: Insights from Cunningham v. Cornell University

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2025-04-28 Current Federal Tax Developments

2025-04-21 Hobby Horse Problems

This week we look at:

• Navigating the 90-Day Deadline for Employment Tax Redeterminations: The Belagio Fine Jewelry, Inc. Case and Equitable Tolling

• GWA, LLC v. Commissioner: Substance Over Form and the Nuances of Tax Elections for Disregarded Entities

• Notice 2025-23: Treasury and IRS Signal Withdrawal of Basis Shifting TOI Regulations and Related Penalties

• Hobby Loss and Failure to File: A Deep Dive into Himmel v. Commissioner

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2025-04-21 Current Federal Tax Developments

2025-04-16 A Very Busy Week as the Deadline Approached

This week we look at:

• Massachusetts Source Income and the Sale of Stock by a Nonresident

• Navigating the Valuation Landscape: Insights from Pierce v. Commissioner

• Personal Liability for Corporate Sales and Use Tax: An Analysis of Matter of the Appeal of B. Wageman

• Navigating the IRS’s ERC Claim Processing Moratorium and "Risking" Procedures

• Jurisdictional Prerequisites in Tax Refund Suits: A Case Study of Estate of Robert F. Armitage, Deceased v. The United States

• Dependency Claims and Child Tax Credits: A Look at Correll v. Commissioner

• WT Art Partnership LP v. Commissioner: Charitable Contribution Deductions and Valuation Pitfalls

• Zajac v. Commissioner: Disallowance of Numerous Deductions and Upholding Penalties

• Hampton v. Commissioner: Public Policy and Disallowance of Shareholder Loss Deduction

• Revised SIFL Rates for Valuation of Noncommercial Flights: Revenue Ruling 2025-9

• IRS Provides Limited Penalty Relief for Certain Micro-Captive Disclosure Statements

• The Demise of DeFi Broker Reporting: An Analysis of H.J. Res. 25

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2025-04-16 Current Federal Tax Developments

2025-04-07 The Cost of Too Good to Be True

This week we look at:

• Ranch Springs, LLC v. Commissioner: A Case Study in the Valuation of Conservation Easements and the Pitfalls of Aggressive Tax Planning

• The Duty of Consistency Prevails: A Case Study in Innocent Spouse Relief and Subsequent Asset Claims

• Navigating the Murky Waters of Investment Tax Credits and Passive Activity Rules: A Deep Dive into Strieby v. Commissioner

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2025-04-07 Current Federal Tax Developments

2025-03-31 End of Paper Tax Payments and Refund Checks Coming

This week we look at:

• Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021

• Interim Final Rule Limiting BOI Filing Requirements Released by Treasury Department

• Substantiating Depreciation for Converted Property: A Look at Smith v. Commissioner

• Executive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related Ones

• Jones et al. v. Commissioner: A Deep Dive into the Tax Court’s Scrutiny of a Microcaptive Insurance Arrangement

• Navigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United States

• Ninth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAs

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2025-03-31 Current Federal Tax Developments

2025-03-24 ERC Simplified Method for Income Tax Reporting

This week we look at:

• TIGTA Report: IRS Refund Claim Processing for Deceased Taxpayers

• IRS Certification of Seriously Delinquent Tax Debt to the State Department

• Refund Claim Challenges: When IRS Guidance Fails

• Sixth Circuit: IRA Forfeiture to Government Not Taxable

• Loper Bright: Pharmacy Benefit Managers Denied DPAD Deduction

• IRS ERC Update: Simplified Income Tax Reporting for Wage Reduction

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2025-03-24 Current Federal Tax Developments

2025-03-17 IRS Guidance on When a Scam Generates a Theft Deduction

This week we look at:

• Tax Court Finds Taxpayer Failed to Provide a Qualified Appraisal, No Charitable Deduction Allowed

• Estate Found Liable for $2 Million FBAR Penalty That Applied to the Decedent

• Taxpayers Filing Court Challenges to Attempt to Obtain Employee Retention Tax Credits

• Fourth Circuit Overturns Trial Court’s Grant of Summary Judgment to the Government, Finding True Issue of Fact Exists Regarding Whether Statute Remained Open

• IRS Memorandum Discusses When a Taxpayer Can Claim a Deduction as Victims of Various Scams Under Current Law

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2025-03-17 Current Federal Tax Developments

2025-03-10 Can We Mostly Ignore BOI Now?

This week we look at:

• Treasury and the Corporate Transparency Act (BOI Reporting)

• Martino v. Commissioner: Alimony Deduction Case

• Estate of Kalikow v. Commissioner: Estate Tax & Settlement Payments

• Appeal of A. Markowski: California Source Income for Nonresidents

• CF Headquarters Corporation v. Commissioner: Taxability of Grants

• United States v. Gora: IRS Levy Enforcement

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Articles for this week’s developments can be downloaded from the link below:

2025-03-10 Current Federal Tax Developments

2025-03-03 FinCEN Announces BOI Relief and Future Actions

This week we look at:

• FinCEN Announcement on BOI Reporting Penalties

• Tax Court Case: Alan Hamel and Estate of Suzanne Hamel v. Commissioner

• IRS “Dirty Dozen” Tax Scams for 2025

• IRS Adds Tax Documents to Online Accounts

• Ways and Means Committee Passes Disaster Relief Bills

• House and Senate Budget Resolutions

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2025-03-03 Current Federal Tax Developments

2025-02-24 BOI Developments Week

This week we look at:

• Second Circuit Rules on Section 179D Deductions and Accounting Method Change

• IRS Guidance on ACA Notice Posting

• Court Case on CPA Negligence and Trust Return Penalties

• BOI Reporting Requirement Updates

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2025-02-25 Current Federal Tax Developments

2025-02-17 A Week of Lost Losses

This week we look at:

• Deductibility of Losses: Weston v. Commissioner

• Conservation Easements: Green Valley Investors LLC

• Automobile Depreciation and Lease Inclusion

• S Corporation Inadvertent Termination Relief

• Corporate Transparency Act (CTA) - Government Briefs

• House Ways & Means Committee Tax Bills

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2025-02-16 Current Federal Tax Developments

2025-02-10 New Administration Pushes Foward with the CTA

This week we look at:

• IRS issues letter ruling on IRA left to trust
• A taxpayer mistakenly believes the IRS had conceded that his income was not subject to self-employment tax, but it hadn’t
• The Tax Court denies a taxpayer’s deductions and claimed partnership losses due to incredibly disorganized and inadequate records
• Taxpayer runs afoul of the “pay first, litigate later” rule when attempting to sue the IRS for a refund in US District Court in response to an assessment
• A taxpayer’s unprocessed claim for an ERTC refund doesn’t justify CDP relief
• The BOI - new Administration continues litigation and proposes a new due date, potential filing relief

An audio only version of this week's broadcast can be downloaded or streamed from the link below.

Article for this week’s developments are available as a PDF from the link below.

2025-02-10 Currrent Federal Tax Developments

2025-02-03 A Week of Tax Court Rulings

This week we look at:

• Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on Return

• IRS Finds Most Expenses Related to Taxpayers’ In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213

• Taxpayer Denied Innocent Spouse Relief in Tax Court Bench Opinion

• Tax Court Finds No Issue With the Appeals Office Structure and Staffing

• Failure to Provide Proof of Filing of Returns Fatal to Taxpayer’s Attempt at Obtaining Relief in CDP Hearing Despite IRS Procedural Errors

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2025-02-03 Current Federal Tax Developments

2025-01-27 BOI Sees Supreme Court Action But There a Catch

This week we look at:

• Funds Taken By Sheriff Were a Valid Loan and Not Income from Embezzlement

• Tax Court Allows a Reduced Deduction for a Conservation Easement

• CCA Discusses Issues with Activities of a Private Foundation with Regard to Self-Dealing, Attempted Correction and Jeopardizing Investments

• IRS Email Discusses Agency’s (Lack of) Obligation to Process Amended Tax Returns

• Supreme Court Reverses Fifth Circuit Merits Panel, Again Removes Emergency Injunction Against Enforcement of the CTA BOI Reports

• Despite Supreme Court’s Action on Texas Top Cop Shop, Inc. Ban on Enforcement of BOI Reporting, FinCEN Notes Ban on Enforcement Under the Smith Case is Still in Effect

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2025-01-27 Current Federal Tax Developments

2025-01-20 SECURE 2.0 Act Proposed Guidance

This week we look at:

• IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 property

• Proposed regulations on catch-up contributions added by the SECURE 2.0 Act

• Proposed regulations on the automatic enrollment provisions of IRC §414A

• US Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process case

• IRS issues final regulations on resolution of tax controversies by the IRS Independent Office of Appeals Under TFA of 2019

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Articles on this week’s developments are contained in the PDF that can be downloaded below.

2025-01-20 Current Federal Tax Developments

2025-01-13 Tax Filing and Payment Relief for California Wildfires and More

This week we look at:

• IRS Grants Tax Relief to California Wildfire Victims

• National Taxpayer Advocate’s Report to Congress and Legislative Recommendations Released

• Third US District Court Issues BOI Reporting Injunction

• Tax Court Finds a Building Was Not a Certified Historic Structure as Defined by §170(h)

• Taxpayer Denied Refund as Court Found the Taxpayer Had Taken the Position That Its Reporting Was an Error Rather Than a Method of Accounting

• Seventh Circuit Upholds Imposition of Fraud Penalty for an Overstatement of Withholdings

• Court Finds Taxpayer Submitted Digitally Altered False Documents, Sustained the Fraud Penalty the IRS Proposed

• IRS Updates Guidance on Section 530 Employment Tax Liability Relief

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2025-01-13 Current Federal Tax Developments

2025-01-06 Digital Assets, BOI, Conservation Easements and Embezzlement

This week we look at:

• IRS gives relief for specific identification of digital asset basis for certain taxpayers for 2025 only

• Department of Justice asks the U.S. Supreme Court to Stay the Latest Corporate Transparency Act Injunction

• IRS no longer to dispute requirement to comply with APA to add listed transactions after the enactment AJCA in 2024

• Tax Court rules that merely being in a registered historic area does not make a building a certified historic structure

• Tax Court finds taxpayer owes tax on over $5.3 million diverted from two retirement plans

An audio only version of this week’s broadcast can be streamed or downloaded below.

A PDF of the slides and links to articles regarding the developments can be downloaded below.

2025-01-05 Current Federal Tax Developments