2026-02-09 Another Former Spouse Ends Up With a Jackpot When Her Ex-Spouse Dies Due to ERISA

This week we look at:

• The "Charitable LLC" Tax Shelter
• Section 280E Bars ERC for Cannabis Businesses
• TEFRA Intervention by Majority Partners
• R&D Credit Substantiation
• Supervisory Approval of Penalties
• ERISA Beneficiary Designations

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• 2026-02-09 Current Federal Tax Developments Articles

• 2026-02-09 Slides

2026-02-02 Paper Refund Checks-Notices and Patience Now

This week we look at:

• Challenging the Presumption of Delivery (CDP Cases)

• Bank Deposits & Conduit Theory

• Mandates Under Executive Order 14247 (Notice CP53E)

• IRS Implementation of Executive Order 14247 - (FS 2026-02)

• Federal Priority Statute Liability

• FASIT Structure & Substantial Compliance

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• 2026-02-02 Current Federal Tax Developments

• 2026-02-02 Slides for Current Federal Tax Developments

2026-01-26 Court Allows ERC Claim to Go Forward-But Throws Out APA Challenge

This week we look at:

• ERC Refund Suits and Challenges to IRS Notice 2021-20

• Section 6015(f) Equitable Relief and Attribution of Income

• Financial Disability Tolling under § 6511(h)

• Distinguishing "Tax Loss" for Sentencing vs. Restitution

• Implementation of Qualified Overtime Deductions (OBBBA)

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• Text - 2026-01-26 Current Federal Tax Developments

• Slides - 2026-01-26 Current Federal Tax Developments Slides

2026-01-19 Fifth Circuit Reverses Tax Court on SE Income for State Law Limited Partners

This week we look at:

• SE Tax Liability for Limited Partners (Sirius Solutions)

• Whistleblower Awards and "Collected Proceeds"

• Statutory Construction of Section 168(k) Amendments

• Updated Safe Harbor Explanations for Section 402(f)

• Modernized Group Tax Exemption Framework

• Tax-Exempt Status of Supplemental Military Housing Allowances

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2026-01-19 Current Federal Tax Developments

2026-01-12 IRS Announces Opening of E-Filing Season for Individuals

This week we look at:

• IRS Announces Filing Season Overview & Timeline

• A Charity Loses Its §501(c)(3) Status After Forgetting to Perform Virtually Any Exempt Activities

• Taxpayer Loses a Large Charitable Contribution Deduction Based on Lack of Substantiation

• Second Circuit Concurs With Other Circuits on Willfulness for FBAR Penalties

• Tax Court Found Summary Assessment Invalid in Premium Tax Credit Case

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2026-01-10 Current Federal Tax Developments

2026-01-05 Proposed Regulations on New Car Loan Interest Deduction

This week we look at:

• Standard Mileage Rates & Notice 2026-10

• 2026 Procedural Updates - Annual Revenue Procedures

• Qualified Passenger Vehicle Loan Interest (QPVLI) Proposed Regulations

• Estate of Spenlinhauer v. Commissioner Late Filing and More

• Bargain Sale of For-Profit colleges to a Non-Profit (501(c)(3))

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2026-01-05 Current Federal Tax Developments

2025-12-29 Marijuana Rescheduling Restarts After Long Pause

This week we look at:

• Executive Action on Marijuana Scheduling and IRC § 280E

• State Paid Family and Medical Leave (PFML) Programs

• Estimated Tax Relief for Qualified Farmland Sales

• IRC § 163(j) Interest Limitation Updates

• Premium Tax Credit (PTC) Revisions

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2025-12-29 Current Federal Tax Developments

2025-12-22 Initial Scholarship Granting Organization Guidance Issued

This week we look at:

• Section 25F Advance Elections

• Unreported Income & The "Missing Witness"

• Constitutionality of Penalties Post-Jarkesy

• Section 280E & Offers-in-Compromise

• Substantiating Bad Debt & NOLs

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2025-12-22 Current Federal Tax Developments

2025-12-15 Postmark Date Risk Due to USPS Change

This week we look at

• USPS Changes to Postmark Date System

• H.R. 1491: Disaster Related Extension of Deadlines Act

• Capitalization Priorities: Temnorod v. Commissioner

• Notice 2026-5: HSA Expansion Under OBBBA

• Fulfillment by Amazon (FBA) and "Doing Business"

• Substantiation Failures: Mirch v. Commissioner

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2025-12-15 Current Federal Tax Developments

2025-12-08 Initial Details Released on Trump Accounts

This week we look at:

• Notice 2025-68 – Implementation of Trump Accounts

• Draft Form 4547 – Elections and Filing Mechanics

• Notice 2025-70 – The OBBBA Scholarship Tax Credit

• Alioto v. Commissioner – Corporate Distinctness

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2025-12-08 Current Federal Tax Developments

2025-12-01 IRS Gives First Discussion of Upcoming Credit for Donation to Tuition Organizations

This week we look at:

• Whistleblower Awards and Substantial Contribution

• Corporate Stock Repurchase Excise Tax

• Judicial Review of Willful FBAR Penalties

• Revisiting the Profit Motive Standard

• Judicial Precedent on Erroneous Refund Recovery

• OBBBA Guidance on SFCs and Section 987 Elections

• The OBBBA Scholarship Tax Credit

• Conservation Easements and Gross Valuation Misstatements

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2025-12-01 Current Federal Tax Developments

2025-11-24 Tips and Overtime Form 1040 Reporting Reiief

This week we look at:

• Innocent Spouse Relief Determination Standards

• Adjustments to Medicare Parts A, B, and D

• Equitable Distribution vs. Alimony (Pre-TCJA)

• Implementation of the Section 139L Interest Exclusion

• OBBBA Deductions for Tips and Overtime Compensation for 2025 returns

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2025-11-24 Current Federal Tax Developments

2025-11-17 Retirement Plan and IRA Inflation Numbers

This week we look at:

• Annual Adjustments to Retirement Plan Limitations

• Ensuring Investment Trust Status for Digital Asset Staking Entities

• Examining Penalties in Microcaptive Transactions

• Ownership Requirements for Non-Business Theft Losses

• Defining the Scope of I.R.C. § 172(b)(3) Carryback Waivers

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2025-11-17 Current Federal Tax Developments

2025-11-10 Employer Guidance for 2025 Qualified Tips and Overtime

This week we look at:

• Conservation Easement Valuation and Highest and Best Use

• Trust Fund Recovery Penalty (TFRP) Application

• California Residency and Taxpayer Burden of Proof

• OBBBA Information Reporting Transition Relief

• SCOTUS Oral Argument on IEEPA Tariffs

• Conservation Easement Timing and Penalties

• Digital Asset Broker Reporting FAQ Guidance

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2025-11-10 Current Federal Tax Developments

2025-11-03 Qualifying Offers in Tax Disputes

This week we look at:

• Private Inurement and Operational Failure

• Prevailing Party Status Under § 7430

• The Federal Priority Statute and Corporate Officer Liability

• Termination of the Automatic Stay in Bankruptcy

• Injunction Violations and Civil Contempt for Tax Preparer

• A Refined Approach to Math Error Notices

• Application of Unstated Interest Rules to Corporate Mergers

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Current Federal Tax Developments November 3, 2025

2025-10-27 More IRS Government Shutdown Clarifications

This week we look at:

• Reevaluating the DC-QIE Exception (FIRPTA)

• Technical Revisions to Revenue Procedure 2025-32

• Transitional Reporting for Qualified Passenger Vehicle Loan Interest (QPVLI)

• Jurisdictional Clarity for TEFRA Readjustment Petitions

• S Corporation Income Attribution and Substantiation Failures

• IRS Operations During a Lapse in Appropriations

• Employee Retention Credit Compliance (OBBBA)

• Form 1099-K Information Reporting Updates

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2025-10-27 Current Federal Tax Developments

2025-10-20 Who Owns a Hotel's ERTC Refund?

This week we look at:

• Employee Retention Credit Refunds in Bankruptcy

• Lawsuit Settlement Enforcement and Tax Disclosure Obligations

• Operational Test Failure: Commercial Activities and Private Benefit

• IRS E-File Suspension Authority

• Taxation of International Investment Losses

• Collection Due Process Analysis

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2025-10-20 Current Federal Tax Developments

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