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

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

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

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

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

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

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

This week we look at

• IRS Updates PTIN User Fee
• Withdrawal of Corporate Reorganization Proposed Regulations
• IRS FY2026 Shutdown Contingency Plan
• Guidance on Rural Qualified Opportunity Zones
• New Interim Guidance on the Corporate AMT
• Tax Relief Extension for Terroristic Action in Israel
• Final Regulations on Interest Capitalization for Improvements
• Eighth Circuit Reverses Tax Court in 3M on Blocked Income
• District Court Finds § 501(c)(4) Standards Unconstitutionally Vague
• Two Tax Court Opinions in Green (Hobby Lobby)

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

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