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.
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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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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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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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
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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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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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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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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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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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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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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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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This week we look at:
Court Frowns on Professional’s Use of Randomly Generated Social Security Numbers
Understanding the “Placed in Service” Rule for Electric Vehicle Credits
Advisers Found to Owe Treble Damages to Impacted Taxpayers
W-2 Wages and the Qualified Business Income Deduction Under Section 280E
Trust Fund Recovery Penalties and Refund Claim Timeliness in Richter v. The United States
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This week we look at:
Eleventh Circuit: Gross Valuation Misstatement Penalty in a Conservation Easement Case
Treasury & IRS: Preliminary Guidance on Tipped Occupations
Eighth Circuit: Medtronic Transfer Pricing Dispute Remanded Again
California OTA: Entertainer Found to be a California Resident
Pitfalls in IRA Bankruptcy Exemptions: Farber v. Feldman
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This week we look at:
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Articles on this week’s developments can be downloaded as a PDF via the link below:
This week we look at:
Federal Complaint Seeking ERC Refunds: Superior Pediatric Care v. United States
Proposed Revisions to Partnership Information Reporting for Sales or Exchanges of Interests—Form 8308
Taxation of Unsolicited Stock Transfers: Analysis of Feige v. Commissioner
Third-Party Intent and the Indefinite Assessment Period: An Analysis of Murrin v. Commissioner
The One, Big, Beautiful Bill Act (OBBBA): New Deductions & Energy Credit Modifications
LLM Limitations in Tax Law: Beyond Memorization
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This week we look at:
Denham Outlines Its Criticisms of the Tax Court’s Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals
Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner
Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility
The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners
Understanding New Clean Electricity Credit Termination Rules Impact of IRS Notice 2025-42 on Wind and Solar Facilities
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This week we look at:
Urgent Guidance Requested on Section 174A Domestic Research and Experimental Expenditures
Post-Referral Authority in Tax Litigation—IRS Lacked Authority to Approve ERC Refund
Closer This Time, But Still Not Quite There—Another Microcaptive Loss for the Taxpayers
Proposed Amendments to IRC Section 132 Fringe Benefit Rules: Switching to NAICS
Understanding Passthrough Losses and Bankruptcy in Field Attorney Advice 20253101F
Proactive Engagement with the Office of Professional Responsibility
IRS Announces Policy for the One Big Beautiful Bill Act for 2025 Payroll Issues
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This week we look at:
Filing Season Forecast to Start in Mid-February in the Coming Season
Settlement Proceeds Found to Be Taxable and Taxpayer Stuck With Late-Filing Penalties
IRS Issues Relief for Certain Issues Related to Partnership Investments and the Corporate Alternative Minimum Tax
Corporate Mergers and the Same Taxpayer Rule for Interest Netting
What Is an Educational Organization for Unrelated Business Income Tax (UBIT) Purposes?
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This week we look at:
Conservation Easement Deductions: A Critical Review of Rock Cliff Reserve, LLC
Portability Election Pitfalls: A Deep Dive into Estate of Rowland and DSUE Requirements
Understanding Equitable Tolling in Tax Court: Insights from Boechler, P.C. v. Commissioner
A Critical Review of Veribest Vesta, LLC v. Commissioner of Internal Revenue: Implications for Conservation Easement Valuations
Understanding Withholding and Reporting for Uncashed Retirement Plan Distribution Checks: A Review of Rev. Rul. 2025-15
Fifth Circuit Affirms Tax Court’s Disallowance of Micro-Captive Insurance Deductions: An Analysis of Swift v. Commissioner
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