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

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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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

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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