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

This week we look at:

• Navigating Corporate Alternative Minimum Tax (CAMT)

• Conservation Easement Valuation & Penalties: A Warning from Tax Court

• Collection Due Process (CDP) & Offers in Compromise (OICs): Lessons from Tax Court

• Accuracy-Related Penalties: Navigating Negligence and Insufficient Professional Reliance

• Understanding Treasury’s Request for Information on Modernizing Federal Payments

• Worthlessness vs. Discharge: A Ninth Circuit Examination of Bad Debt Deductions Concurrent with COD Income

• Navigating the Religious Exemption Landscape: A Deep Dive into Unemployment Compensation Tax

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2025-06-09 Current Federal Tax Developments

This week we look at:

• IRS Reduces Estate Tax Closing Letter Fee

• Tax Court Scope of Review in Passport Cases

• Marital Deduction for Bequests to Trust

• “Reasonable Cause” in Late-Filing Penalty Cases

• “No Tax on Tips Act” (S.129) Passes Senate

• Transfer Pricing in Facebook, Inc. & Subsidiaries v. Commissioner

• Navigating New York’s Convenience Rule: Insights from Matter of Zelinsky

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2025-05-26 Current Federal Tax Developments

This week we look at:

• IRC Section 7433 and the Scope of the Collection Waiver of Sovereign Immunity

• The Claim of Right Doctrine Applied to Business Errors

• IRC Section 7433: Reinforcing Collection vs. Assessment Distinction

• Selected issues from The One, Big, Beautiful Bill’s tax provisions

• Proposed Changes to the Section 199A Qualified Business Income Deduction

• Proposed Changes Affecting Passthrough Entities and State PTE Taxes

• Interest Deductions and Penalties in Complex Financial Transactions

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2025-05-19 Current Federal Tax Developments

This week we look at:

• Deductibility of IVF and Gestational Surrogacy Costs

• Fraudulent Tax Claims & 28 U.S.C. § 2514

• Tax Collection Suits & Statute of Limitations in United States v. Ragen

• Moving Expense Deduction - Civilian Department of Defense Contractor Eligibility

• Tax Court Jurisdiction - The 90-Day Deadline for Deficiency Petitions

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2025-05-12 Current Federal Tax Developments