Keeping CPAs Up to Date on Tax Matters

A site devoted to articles on current developments in federal taxes geared toward CPAs in tax practice.

2026-07-06 ERC Cases Galore Week

July 05, 2026 by Ed Zollars, CPA

This week we look at:

Section 7508A(d) and Interest on Pre-COVID-19 Disaster Tax Deficiencies
The Soroban Capital Partners SECA Tax Controversy
Pleading Requirements for the Employee Retention Credit (Tapestry Senior Housing)
ERC Causation and the Essential Business Hurdle (RAAM Construction)
The Section 530A Transfer Tax Safe Harbor (Rev. Proc. 2026-25)
Penalty Supervisory Approval Verification in CDP (Besicorp Group)
Retroactive ERC Deadlines & Constitutional Challenges

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2026-06-29 OPR Releases Guidance On use of Generative AI

June 28, 2026 by Ed Zollars, CPA

This week we look at;

Nominal S Corporation Ownership and the Abuse Exception
Recapping the ERC via Section 7405 Civil Actions
Constructive Dividends, Formalities, and Civil Fraud
CDP Hearings, Offer-In-Compromise, and RCP Calculations
Professional Responsibility and Responsible AI Use
Rigorous Proof for ERC "Partial Suspension" Claims

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PDFs with this week’s articles on the updates and the slides used for this week’s presentation can be downloaded below.

2026-06-15 Trusts and the New Section 68

June 12, 2026 by Ed Zollars, CPA

This week we look at:

Application of New Section 68 to Trusts and Estates
Assessing the Risks of Hindsight in Late § 475(f)(1) Elections
The Eradication of the 5% Safe Harbor (Clean Energy)
Limits of § 2036(a) and Tax-Motivated Transfers
Section 183 Hobby Losses & Penalties
New Section 25F Education Freedom Tax Credit

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PDFs with copies of this week’s articles on the updates and the slides for this week can be downloaded below:

2026-06-08 An Inconsistent Tale of Two ERC Court Rulings

June 07, 2026 by Ed Zollars, CPA

This week we look at:

Proposed Increase to Estate Tax Closing Letter User Fee
Divergent Causation Standards for ERC Eligibility
Valuation Extremes in Conservation Easements
Substantiating Mortgage Interest Deductions
Taxation of Cryptocurrency Staking Rewards
Section 4960 and "Covered Employees"
FBAR Compliance and IRS Agent Authority

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Articles related to this week’s updates and slides for the week’s program can be downloaded below.

2026-06-01 More Details on the Activation of Trump Accounts

May 31, 2026 by Ed Zollars, CPA

This week we look at:

Procedural Timeliness & Automatic Extensions
Spousal IRA Rollovers Through Estates and Trusts
Collateral Estoppel and the "Innocent" Spouse
Improper Corporate Deductions and Fraud
Implementation of "Trump Accounts"
2027 Inflation Adjustments (HSA, HRA, DPCSA)

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2026-05-25 IRS Prepares to Challenge Kwong After Limited AOD on Abdo

May 25, 2026 by Ed Zollars, CPA

This week we look at:

Equitable Relief for Erroneous Tax Refunds: An Analysis of the Fourth Circuit's Reversal in LaRosa v. Commissioner
Final Regulations Modify Information Reporting for Section 751(a) Partnership Interest Exchanges
The Impermeable Reach of Section 6672: Joint and Several Trust Fund Liability and the Demise of the Delegation Defense
The Taxpayer Due Process Enhancement Act (H.R. 6506): A Crucial Legislative Response to Commissioner v. Zuch
Demystifying Notice 2026-33: Comprehensive Guidance on Qualified Long-Term Care Distributions under the SECURE 2.0 Act
IRS Action on Decision: Decoding the Service’s Limited Acquiescence on Mandatory COVID-19 Postponements and the Road Ahead in Kwong

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2026-05-25 Current Federal Tax Developments

Slides for week of May 25, 2026

2026-05-18 If a Client Claims Charitable Contributions You Must Understand the CWA Rules

May 17, 2026 by Ed Zollars, CPA

This week we look at:

Technical Analysis of the Proposed Regulations Establishing Excepted Fertility Benefits
Analysis of the IRS Time-Limited Settlement Initiative for Conservation Easement Disputes
Strict Compliance with Contemporaneous Written Acknowledgment Requirements in Charitable Land Contributions
Transferee Tax Liability and the Consequences of Willful Blindness: An Analysis of Dillon Trust Company v. United States

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2026-05-18 Current Federal Tax Developments

Slides for May 18, 2026 Current Federal Tax Developments

2026-05-11 The Expensive Lost White Receipt and Certified Mailing

May 10, 2026 by Ed Zollars, CPA

This week we look at:

Syndicated Conservation Easements and the Valuation Conundrum: An Analysis of T.C. Memo. 2026-36
Analysis of Garcia-Rojas v. Franchise Tax Board: The Limits of the Unitary Business Doctrine for Sole Proprietors
An Analysis of the Reinstated Significant Issue Letter Ruling Program Under Revenue Procedure 2026-21
The "Byers Rule" and the Administrative Procedure Act
Jurisdictional Time Bars and the Timely Mailing Rule: An Analysis of Dunlap v. United States
Temporary Import Surcharges and Executive Authority: A Review of the Court of International Trade's Ruling

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2026-05-11 Current Federal Tax Developments

Slides for Current Federal Tax Developments

2026-05-04 Treasury Previews Upcoming 280E Medical Marijuana Guidance

May 03, 2026 by Ed Zollars, CPA

This week we look at:

Reasonable Cause Relief Under the Small-Corporation Provision for Form 5472 Penalties
Extending the Statute of Limitations for Disallowed ERC Claims
Legislative Update: House Passes Comprehensive Tax Administration and Relief Bills
Anticipated IRS Guidance Following the Rescheduling of Medical Marijuana
Analysis of the New Dyed Fuel Excise Tax Refund Regulations Under Section 6435
Executive Order on Retirement Savings and Its Interaction with IRC Section 6433

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Articles for this week and slides can be downloaded below:

2026-04-27 No More 280E for State-Legal Medical Cannabis Businesses

April 25, 2026 by Ed Zollars, CPA

This week we look at:

Tax Implications of the Rescheduling of State-Licensed Medical Marijuana
Disallowance of COVID-19 Leave Credits: A Review of Substantiation and Trade or Business Requirements
Substantiation, Entity Indebtedness, and Business Expense Deductibility: An Analysis of the Simmons Case
The Tenth Circuit Codifies the Reach of the Economic Substance Doctrine Over Mechanical Statutory Compliance
Treatment of Loyalty Rewards Program Funds and the Claim of Right Doctrine
Valuation and Penalty Controversies in Estate Tax Examinations

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The text of the articles for this week’s update and the slides (with infographics) can be downloaded below:

2026-04-20 Final Regulations Issued on Qualified Tip Income

April 19, 2026 by Ed Zollars, CPA

This week we look at:

A Technical Analysis of the Final Section 224 Regulations on the Qualified Tip Deduction
Analysis of Proposed Regulations on Information Reporting Thresholds and Wagering Losses (REG-113229-25)
U.S. District Court Splits Its Ruling on Micro-Captive Disclosure Mandates
IRS Reduces Enrolled Agent Special Enrollment Examination User Fees: An Analysis of the Interim Final and Proposed Regulations
Taxation of Terminated Life Insurance Policies: An Analysis of Constructive Receipt and Investment Interest

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You can download materials related to this week’s updates below:

2026-04-20 Text of Update Articles
Slide Presentation

2026-03-23 Claim of Right and the Correct Tax Year

March 22, 2026 by Ed Zollars, CPA

This week we look at:

Corporate Capacity and State Law Revivor
Digital Asset Identification Relief
Interest and Bonus Depreciation Relief
ERC Disallowances and Legal Standing
Substantiation Rules for Emergency Vehicles
Partnership Audits and Due Process
Social Security Repayments

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PDFs with the articles for this week’s update and the slides can be downloaded below:

2026-03-16 Trump Account Proposed Regulations

March 15, 2026 by Ed Zollars, CPA

This week we look at:

Proposed Regulations for IRC Section 530A "Trump Accounts"
IRC Section 6434 Trump Account Pilot Program
Micro-Captive Scrutiny Formalized
BBA Audits: Notice Defects and the Statute of Limitations

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Articles for this week’s update and a copy of the slides for this week can be downloaded below as PDFs:

2026-03-09 Sir You Are About to Lose Your Passport

March 08, 2026 by Ed Zollars, CPA

This week we look at:

Fiduciary and Beneficiary Liability for Unpaid Estate Taxes
Retroactive Entity Classification and Partnership Basis
2026 Passenger Auto Depreciation Limits
Passport Certification & Victimization Defenses
Passport Revocation in Collection Suits
Waiver of Foreign Earned Income Exclusion Time Rules
New Digital Asset Reporting Landscape (Form 1099-DA)

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This week’s update articles and slides can be downloaded below:

2026-03-02 Another Circuit Find IRS Has Assessment Authority for Section 6038(b) Penalties

March 01, 2026 by Ed Zollars, CPA

This week we look at:

Required Minimum Distribution Regulations Delay
CDP Proceedings and Underlying Liabilities
Section 743(b) Adjustments and Economic Substance
Assessability of Section 6038(b) Penalties

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2026-02-23 Supreme Court Strikes Down Tariffs

February 22, 2026 by Ed Zollars, CPA

This week we look at:

Supreme Court Invalidates Executive Tariffs Under IEEPA
Special Depreciation Allowance Under the OBBBA
CAMT Adjustments and Relief
Circuit Split on Third-Party Fraud
Valuation and Penalties in Syndicated Conservation Easements

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PDFs with the articles for this week’s update and copies of the slides can be dowloaded below:

2026-02-16 Hallucinations Enter the Tax Court

February 15, 2026 by Ed Zollars, CPA

This week we look at:

TEFRA Jurisdiction and the "Limited Partner" Exception
Artificial Intelligence and Substantiation
Section 183 Profit Motive
Rebate vs. Nonrebate Refunds
Substantiation and Civil Fraud
Consolidated Return Jurisdiction

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

February 08, 2026 by Ed Zollars, CPA

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

January 31, 2026 by Ed Zollars, CPA

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

January 25, 2026 by Ed Zollars, CPA

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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The PDFs for this week’s updates and slides are available via the links below:

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