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

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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

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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

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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

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2025-12-01 Current Federal Tax Developments

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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A PDF with this week’s updates can be downloaded via the link below.

2025-11-17 Current Federal Tax Developments

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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2025-11-10 Current Federal Tax Developments

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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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

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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

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2025-10-20 Current Federal Tax Developments