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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2025-08-25 Stump the LLM

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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2025-08-18 Current Federal Tax Developments

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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2028-08-11 Current Federal Tax Developments

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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2028-08-02 Current Federal Tax Developments

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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2025-07-21 Current Federal Tax Developments

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

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

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

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

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