Current Federal Tax Developments

This week we look at:

• ERC Claims Filed Without Schedule R

• Reasonable Cause for Information Return Penalties: Reliance on Software

• Proposed Expansion of P.L. 86-272 "Solicitation of Orders" Definition

• 2026 Inflation Adjustments for HSAs and Excepted Benefit HRAs

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

A PDF with articles on this week’s updates can downloaded as a PDF below:

2025-05-05 Current Federal Tax Developments

This week we look at:

• Navigating the Overlap: Civil Tax Assessments and Criminal Restitution Orders

• Navigating Innocent Spouse Relief: A Look at Salvi v. Commissioner

• Supreme Court Weighs Tax Court Jurisdiction in Levy Disputes After Tax Payment: A Deep Dive into Commissioner v. Zuch

• Navigating ERISA Prohibited Transaction Claims: Insights from Cunningham v. Cornell University

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

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

2025-04-28 Current Federal Tax Developments

This week we look at:

• Navigating the 90-Day Deadline for Employment Tax Redeterminations: The Belagio Fine Jewelry, Inc. Case and Equitable Tolling

• GWA, LLC v. Commissioner: Substance Over Form and the Nuances of Tax Elections for Disregarded Entities

• Notice 2025-23: Treasury and IRS Signal Withdrawal of Basis Shifting TOI Regulations and Related Penalties

• Hobby Loss and Failure to File: A Deep Dive into Himmel v. Commissioner

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

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

2025-04-21 Current Federal Tax Developments

This week we look at:

• Massachusetts Source Income and the Sale of Stock by a Nonresident

• Navigating the Valuation Landscape: Insights from Pierce v. Commissioner

• Personal Liability for Corporate Sales and Use Tax: An Analysis of Matter of the Appeal of B. Wageman

• Navigating the IRS’s ERC Claim Processing Moratorium and "Risking" Procedures

• Jurisdictional Prerequisites in Tax Refund Suits: A Case Study of Estate of Robert F. Armitage, Deceased v. The United States

• Dependency Claims and Child Tax Credits: A Look at Correll v. Commissioner

• WT Art Partnership LP v. Commissioner: Charitable Contribution Deductions and Valuation Pitfalls

• Zajac v. Commissioner: Disallowance of Numerous Deductions and Upholding Penalties

• Hampton v. Commissioner: Public Policy and Disallowance of Shareholder Loss Deduction

• Revised SIFL Rates for Valuation of Noncommercial Flights: Revenue Ruling 2025-9

• IRS Provides Limited Penalty Relief for Certain Micro-Captive Disclosure Statements

• The Demise of DeFi Broker Reporting: An Analysis of H.J. Res. 25

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

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

2025-04-16 Current Federal Tax Developments

This week we look at:

• Ranch Springs, LLC v. Commissioner: A Case Study in the Valuation of Conservation Easements and the Pitfalls of Aggressive Tax Planning

• The Duty of Consistency Prevails: A Case Study in Innocent Spouse Relief and Subsequent Asset Claims

• Navigating the Murky Waters of Investment Tax Credits and Passive Activity Rules: A Deep Dive into Strieby v. Commissioner

An audio only broadcast can be downloaded or streamed below:

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

2025-04-07 Current Federal Tax Developments

This week we look at:

• Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021

• Interim Final Rule Limiting BOI Filing Requirements Released by Treasury Department

• Substantiating Depreciation for Converted Property: A Look at Smith v. Commissioner

• Executive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related Ones

• Jones et al. v. Commissioner: A Deep Dive into the Tax Court’s Scrutiny of a Microcaptive Insurance Arrangement

• Navigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United States

• Ninth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAs

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

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

2025-03-31 Current Federal Tax Developments

This week we look at:

• TIGTA Report: IRS Refund Claim Processing for Deceased Taxpayers

• IRS Certification of Seriously Delinquent Tax Debt to the State Department

• Refund Claim Challenges: When IRS Guidance Fails

• Sixth Circuit: IRA Forfeiture to Government Not Taxable

• Loper Bright: Pharmacy Benefit Managers Denied DPAD Deduction

• IRS ERC Update: Simplified Income Tax Reporting for Wage Reduction

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

The articles for this week’s developments can be downloaded below:

2025-03-24 Current Federal Tax Developments

This week we look at:

• Tax Court Finds Taxpayer Failed to Provide a Qualified Appraisal, No Charitable Deduction Allowed

• Estate Found Liable for $2 Million FBAR Penalty That Applied to the Decedent

• Taxpayers Filing Court Challenges to Attempt to Obtain Employee Retention Tax Credits

• Fourth Circuit Overturns Trial Court’s Grant of Summary Judgment to the Government, Finding True Issue of Fact Exists Regarding Whether Statute Remained Open

• IRS Memorandum Discusses When a Taxpayer Can Claim a Deduction as Victims of Various Scams Under Current Law

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

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

2025-03-17 Current Federal Tax Developments

This week we look at:

• Treasury and the Corporate Transparency Act (BOI Reporting)

• Martino v. Commissioner: Alimony Deduction Case

• Estate of Kalikow v. Commissioner: Estate Tax & Settlement Payments

• Appeal of A. Markowski: California Source Income for Nonresidents

• CF Headquarters Corporation v. Commissioner: Taxability of Grants

• United States v. Gora: IRS Levy Enforcement

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

Articles for this week’s developments can be downloaded from the link below:

2025-03-10 Current Federal Tax Developments

This week we look at:

• FinCEN Announcement on BOI Reporting Penalties

• Tax Court Case: Alan Hamel and Estate of Suzanne Hamel v. Commissioner

• IRS “Dirty Dozen” Tax Scams for 2025

• IRS Adds Tax Documents to Online Accounts

• Ways and Means Committee Passes Disaster Relief Bills

• House and Senate Budget Resolutions

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

A copy of the articles for this week’s broadcast can be downloaded below:

2025-03-03 Current Federal Tax Developments