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.

2025-07-14 Passage of a Much Shorter Additional Tax Bill

July 14, 2025 by Ed Zollars, CPA

This week we look at:

Recent Developments: Interpreting the Johnson Amendment in Tax-Exempt Status Litigation
An Examination of Contract Formation in Tax Court Settlement: Insights from Arden Row Assets, LLC
Jurisdictional Imperatives in Tax Court: A Case Study on Timeliness and Last Known Address
Expanding Horizons: Potential Changes to Disaster Tax Relief Under the Filing Relief for Natural Disasters Act

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2025-07-14 Current Federal Tax Developments

2025-07-07 Win Some Lose Some on Statutes of Limitations for the IRS

July 07, 2025 by Ed Zollars, CPA

This week we look at:

Bad Debt Deduction and Accuracy-Related Penalties: Key Takeaways from Anaheim Arena Management, LLC v Commissioner
FBAR Compliance and the CPA’s Due Diligence Under Circular 230
Dissecting Partnership Audit Limitations: Insights from JM Assets, LP v. Commissioner
Decoding Penalty Assessments: A Deep Dive into Moxon Corporation v. Commissioner
Tax Court Scrutiny: Upholding Civil Fraud Penalties in Beleiu v. Commissioner

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2025-07-07 Current Federal Tax Developments

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

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2025-06-30 Current Federal Tax Developments

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

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2025-06-23 Current Federal Tax Developments

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

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2025-06-16 Current Federal Tax Developments

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

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2025-06-09 Current Federal Tax Developments

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)

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2025-06-02 Current Federal Tax Developments

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

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2025-05-26 Current Federal Tax Developments

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

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2025-05-19 Current Federal Tax Developments

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

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2025-05-12 Current Federal Tax Developments

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

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2025-05-05 Current Federal Tax Developments

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

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2025-04-28 Current Federal Tax Developments

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

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2025-04-21 Current Federal Tax Developments

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

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2025-04-16 Current Federal Tax Developments

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

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2025-04-07 Current Federal Tax Developments

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

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2025-03-31 Current Federal Tax Developments

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

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2025-03-24 Current Federal Tax Developments

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

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