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

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

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

Current Federal Tax Developments November 3, 2025

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

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

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

2025-10-27 Current Federal Tax Developments

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

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

A PDF with this week’s articles for the updates can be found at:

2025-10-20 Current Federal Tax Developments

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

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

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

2025-10-13 Current Federal Tax Developments

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

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

You can download a PDF of articles for this week’s updates via the link below:

2025-09-29 Current Federal Tax Developments

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

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

A PDF with this week’s articles on the updates can be downloaded via the link below:

2025-09-22 Current Federal Tax Developments

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

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

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

2025-09-15 Current Federal Tax Developments

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

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

A PDF file with this week’s articles on the developments can be downloaded via the link below:

2025-09-06 Current Federal Tax Developments

This week we look at:

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:

2025-09-02 Current Federal Tax Developments

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

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

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

2025-08-25 Stump the LLM