This week we look at:

• Challenging the Presumption of Delivery (CDP Cases)

• Bank Deposits & Conduit Theory

• Mandates Under Executive Order 14247 (Notice CP53E)

• IRS Implementation of Executive Order 14247 - (FS 2026-02)

• Federal Priority Statute Liability

• FASIT Structure & Substantial Compliance

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

A copy of the articles and slides can be downloaded as PDFs below:

• 2026-02-02 Current Federal Tax Developments

• 2026-02-02 Slides for Current Federal Tax Developments

This week we look at:

• ERC Refund Suits and Challenges to IRS Notice 2021-20

• Section 6015(f) Equitable Relief and Attribution of Income

• Financial Disability Tolling under § 6511(h)

• Distinguishing "Tax Loss" for Sentencing vs. Restitution

• Implementation of Qualified Overtime Deductions (OBBBA)

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

The PDFs for this week’s updates and slides are available via the links below:

• Text - 2026-01-26 Current Federal Tax Developments

• Slides - 2026-01-26 Current Federal Tax Developments Slides

This week we look at:

• SE Tax Liability for Limited Partners (Sirius Solutions)

• Whistleblower Awards and "Collected Proceeds"

• Statutory Construction of Section 168(k) Amendments

• Updated Safe Harbor Explanations for Section 402(f)

• Modernized Group Tax Exemption Framework

• Tax-Exempt Status of Supplemental Military Housing Allowances

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

Articles on this week’s update can be downloaded as a PDF via the link below:

2026-01-19 Current Federal Tax Developments

This week we look at:

• IRS Announces Filing Season Overview & Timeline

• A Charity Loses Its §501(c)(3) Status After Forgetting to Perform Virtually Any Exempt Activities

• Taxpayer Loses a Large Charitable Contribution Deduction Based on Lack of Substantiation

• Second Circuit Concurs With Other Circuits on Willfulness for FBAR Penalties

• Tax Court Found Summary Assessment Invalid in Premium Tax Credit Case

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

Articles for this week’s update can be downloaded as a PDF below:

2026-01-10 Current Federal Tax Developments

This week we look at:

• Standard Mileage Rates & Notice 2026-10

• 2026 Procedural Updates - Annual Revenue Procedures

• Qualified Passenger Vehicle Loan Interest (QPVLI) Proposed Regulations

• Estate of Spenlinhauer v. Commissioner Late Filing and More

• Bargain Sale of For-Profit colleges to a Non-Profit (501(c)(3))

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

Articles on this week’s updates can be downloaded in the PDF below:

2026-01-05 Current Federal Tax Developments

This week we look at:

• Executive Action on Marijuana Scheduling and IRC § 280E

• State Paid Family and Medical Leave (PFML) Programs

• Estimated Tax Relief for Qualified Farmland Sales

• IRC § 163(j) Interest Limitation Updates

• Premium Tax Credit (PTC) Revisions

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

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

2025-12-29 Current Federal Tax Developments

This week we look at:

• Section 25F Advance Elections

• Unreported Income & The "Missing Witness"

• Constitutionality of Penalties Post-Jarkesy

• Section 280E & Offers-in-Compromise

• Substantiating Bad Debt & NOLs

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

Articles for this week’s update can be streamed or downloaded below:

2025-12-22 Current Federal Tax Developments

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

An audio only update can be downloaded or streamed below:

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

2025-12-15 Current Federal Tax Developments

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

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

Articles for this week’s broadcast can be downloaded as a PDF below.

2025-12-08 Current Federal Tax Developments

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

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

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

2025-12-01 Current Federal Tax Developments