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

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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

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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

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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

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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

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2025-09-06 Current Federal Tax Developments

This week we look at:

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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

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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