Current Federal Tax Developments

Keeping CPAs Up to Date on Tax Matters

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2025-06-30 ERC Issues Return to Court

June 30, 2025 by Ed Zollars, CPA

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

An audio recording of this week’s broadcast can be streamed or downloaded below:

Articles on this week’s developments can be downloaded as a PDF below.

  • 2025-06-30 Current Federal Tax Developments

June 30, 2025 /Ed Zollars, CPA
Comment

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

June 22, 2025 by Ed Zollars, CPA

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

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

A PDF of the articles for this week’s update can be downloaded below:

2025-06-23 Current Federal Tax Developments

June 22, 2025 /Ed Zollars, CPA
Comment

2025-06-16 The Case of the Vanishing Levy

June 16, 2025 by Ed Zollars, CPA

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

An audio only version of this week’s update can be streamed or downloaded below:

A PDF with articles on this week’s developments can be downloaded below:

2025-06-16 Current Federal Tax Developments

June 16, 2025 /Ed Zollars, CPA
Comment

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

June 08, 2025 by Ed Zollars, CPA

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

An audio-only version of this week broadcast can be streamed or downloaded via the link below:

This week’s articles on the updates are available in the PDF that can be downloaded below:

2025-06-09 Current Federal Tax Developments

June 08, 2025 /Ed Zollars, CPA
Comment

2025-06-02 Revisiting Previously Discussed Cases

June 02, 2025 by Ed Zollars, CPA

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)

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

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A PDF with the articles for this week’s updates can be downloaded below:

2025-06-02 Current Federal Tax Developments

June 02, 2025 /Ed Zollars, CPA
Comment

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

May 26, 2025 by Ed Zollars, CPA


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

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

A PDF with the text of articles on this week’s update can be downloaded below.

2025-05-26 Current Federal Tax Developments

May 26, 2025 /Ed Zollars, CPA
Comment

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

May 18, 2025 by Ed Zollars, CPA

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

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

A PDF with articles on this week’s developments can be downloaded below.

2025-05-19 Current Federal Tax Developments

May 18, 2025 /Ed Zollars, CPA
Comment

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

May 09, 2025 by Ed Zollars, CPA

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

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

A PDF with this week’s articles can be downloaded below:

2025-05-12 Current Federal Tax Developments

May 09, 2025 /Ed Zollars, CPA
Comment

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

May 02, 2025 by Ed Zollars, CPA

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

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

A PDF with articles on this week’s updates can downloaded as a PDF below:

2025-05-05 Current Federal Tax Developments

May 02, 2025 /Ed Zollars, CPA
Comment

2025-04-28 Twice to the Supreme Court

April 25, 2025 by Ed Zollars, CPA

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

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

Articles on this week’s updates can be downloaded as a PDF below:

2025-04-28 Current Federal Tax Developments

April 25, 2025 /Ed Zollars, CPA
Comment

2025-04-21 Hobby Horse Problems

April 18, 2025 by Ed Zollars, CPA

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

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

Articles on this week’s developments can be downloaded as a PDF below:

2025-04-21 Current Federal Tax Developments

April 18, 2025 /Ed Zollars, CPA
Comment

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

April 16, 2025 by Ed Zollars, CPA

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

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

A PDF with articles on this week’s update can be downloaded below:

2025-04-16 Current Federal Tax Developments

April 16, 2025 /Ed Zollars, CPA
Comment

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

April 06, 2025 by Ed Zollars, CPA

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

An audio only broadcast can be downloaded or streamed below:

Articles on this week’s developments and citations can be downloaded below:

2025-04-07 Current Federal Tax Developments

April 06, 2025 /Ed Zollars, CPA
Comment

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

March 30, 2025 by Ed Zollars, CPA

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

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

Articles on this week’s update can be downloaded below:

2025-03-31 Current Federal Tax Developments

March 30, 2025 /Ed Zollars, CPA
Comment

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

March 24, 2025 by Ed Zollars, CPA

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

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

The articles for this week’s developments can be downloaded below:

2025-03-24 Current Federal Tax Developments

March 24, 2025 /Ed Zollars, CPA
Comment

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

March 16, 2025 by Ed Zollars, CPA

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

An audio only version of this week’s broadcast can be downloaded or streamed from this link:

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

2025-03-17 Current Federal Tax Developments

March 16, 2025 /Ed Zollars, CPA
Comment

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

March 09, 2025 by Ed Zollars, CPA

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

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

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

2025-03-10 Current Federal Tax Developments

March 09, 2025 /Ed Zollars, CPA
Comment

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

March 02, 2025 by Ed Zollars, CPA

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

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

A copy of the articles for this week’s broadcast can be downloaded below:

2025-03-03 Current Federal Tax Developments

March 02, 2025 /Ed Zollars, CPA
Comment

2025-02-24 BOI Developments Week

February 23, 2025 by Ed Zollars, CPA

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

An audio only version of this week’s broadcast can be downloaded below:

The articles and citations for this week’s broadcast can be downloaded as a PDF from the link below:

2025-02-25 Current Federal Tax Developments

February 23, 2025 /Ed Zollars, CPA
Comment

2025-02-17 A Week of Lost Losses

February 16, 2025 by Ed Zollars, CPA

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

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

The articles for this week’s update can be downloaded below:

2025-02-16 Current Federal Tax Developments

February 16, 2025 /Ed Zollars, CPA
Comment
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