Federal Tax Update Podcast

This week we look at:

Informal claim and COVID-19 disaster relief save an untimely-looking IRA refund suit in Singh. IRS recasts "Section 351 conversion" ETF transactions as taxable exchanges in Rev. Rul. 2026-20. Proposed regs implement a four-year installment election for farmland sales to young farmers. A corporate Offer-in-Compromise caps an officer's Trust Fund Recovery Penalty liability in Amodio. Treasury completes automatic enrollment in Trump Accounts under new Section 530A regulations. Sevillo Fine Foods: three independent grounds doom an ERC claim based on port congestion delays. Tax Court holds Form 872-T cannot terminate a fixed-date Form 872 extension in Fine v. Commissioner. New IRS notice extends tax deadlines to September 2027 for Israel conflict-affected taxpayers. Congress sends the National Taxpayer Advocate independent legal counsel in H.R. 997. New regulations build the infrastructure for the $1,700 Section 25F scholarship tax credit.

This week we look at:

• Tax Court Applies Equitable Tolling to BBA Partnership Petition Deadlines -- Kings Road Property
• District Court Voids VIBIR's Net Investment Income Tax Assessment -- Perkins
• IRS Notice 2026-55 Seeks Comments on Opportunity Zone Rules for Housing Developers
• Hurricane Michael Casualty and Charitable Deductions Fail for Lack of Substantiation -- Williams
• Treasury Raises the Estate Tax Closing Letter User Fee to $76 -- TD 10055
• Tax Court Finds Proper Mailing Despite a Defective Form 3877 -- Lindsey
• Unsubstantiated Insider Loan Triggers 225-Percent Excise Tax Exposure -- Jagannath

This week we look at:

• Tax Court Warns of AI Drafting Pitfalls in a CDP Lien Withdrawal Case -- Moore
• Altering the Perjury Jurat Dooms a Refund Suit -- Johnson v. IRS
• IRS Extends the Involuntary Conversion Period for Drought-Hit Livestock Sales
• H.R. 9500 Would Restore and Expand Personal Casualty and Theft Loss Relief
• Second Circuit Rejects Form Over Function for SECA Tax -- Soroban Capital Partners
• H.R. 5334 Expands the Educator Expense Deduction to Early Childhood Teachers

This week we look at:

• Final Regulations Restore the Car Loan Interest Deduction Under T.D. 10054
• Fourth Circuit Affirms $2.9M Willful FBAR Penalty -- United States v. Rund
• Tax Court Clarifies BBA Extension Mechanics -- Katanga Properties
• Treasury Proposes Sweeping QOF Certification and Reporting Regulations
• Proposed Regs Allocate Foreign Source Deductions Under Sections 250 and 904
• Unrestricted $16.5M Art Deal Funds Are Taxable Income -- Tunkl v. Commissioner

This week we look at:

• Federal Circuit Bars Treaty FTCs Against the NIIT -- Bruyea and Christensen

• Financial Disability Tolling and Third-Party Authorization -- Goldman v. United States

• OIC Public-Policy Rejections Upheld -- Filipowski v. Commissioner

• Substantiation and Alter-Ego Doctrine -- Hank Risan v. Commissioner

• Codifying Racial Nondiscrimination for Private Schools -- Proposed Section 1.501(c)(3)-2

• IRS's Certified-Mailing Burden of Proof -- Wales v. Commissioner

• Automatic Accounting Method Changes for R&E and Construction -- Rev. Proc. 2026-32

This week we look at:

• Zero-Return Form 1065 Filings and the Beard Test (IRS CCA 202634014)
• Full Payment Rule & Presumption of Correctness -- Pellegrino v. United States
• Pro Rata Share Determinations Under OBBBA -- Proposed Regulations (REG-115646-25)
• Treaty Exclusivity for Pooled Investments -- South Saskatchewan Community Foundation v. U.S.

This week we look at:

• Form 1041-A Relief for Passthrough Charitable Deductions (REG-109082-25)
• Vested Development Rights & Easement Valuation — Malibu Valley Land v. Commissioner
• First Circuit Bars Equitable Tolling of Section 6213(a) — Kyick Holdings v. Commissioner
• PRWORA Immigration Restrictions on Refundable Credits (REG-119882-25)
• Single-Employer DB Pension Funding Proposed Regulations (REG-107855-25)
• Excluded Property Sales Income Under Section 250 (REG-117130-25)
• Section 163(j) Business Interest Limitation Update — Fact Sheet FS-2026-14
• Doug LaMalfa Federal Disaster Tax Relief Certainty Act (H.R. 5366)
• IRS Ends Uniform Easement Settlement Initiative, Creates Office of Conservation Easements
• Trump Account Eligible Investment Rules — Proposed Regulations (RIN 1545-BS14)

This week we look at:

• Unpacking the Saver's Match: Technical Guidance and Operational Frameworks Under Notice 2026-48
• Harmonizing Section 3406 Backup Withholding with Section 6050W De Minimis Reporting Thresholds
• The High Bar for Equitable Tolling in Tax Practice: The Eighth Circuit's Final Ruling in Boechler, P.C.
• Employer Contributions to Trump Accounts and Nondiscrimination Rules under REG-101355-26
• The Perpetual Burden of Carryover Substantiation: AMT Credits and Recordkeeping in Beacom v. Commissioner
• Equitable Tolling of Tax Court Filing Deadlines: Maniktala v. Commissioner (8th Cir.)
• Standardizing Retirement Plan Rollovers and Trustee-to-Trustee Transfers under SECURE 2.0: Notice 2026-49
• Unmasking the $70 Million Dubai Fraud: Section 165 Theft Loss Deductions in Deutsch v. Commissioner
• Treasury Proposes Substantive Section 987 Relief for Controlled Foreign Corporations (REG-103844-26)
• Rehearing Reversal: The Fifth Circuit's Management Test for the Limited Partner Exception (K Alain, L.L.L.P.)
• The Crucial Role of Highest and Best Use in Conservation Easement Valuations: Evans v. Commissioner

This week we look at:

• Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4)
• Trustee-to-Trustee Transfers of Inherited IRAs Through an Estate: Technical Analysis of PLR 202631001
• Federal Courts Lack APA Jurisdiction Over Foreign Gift Penalty Disputes: The Adequate Alternative Remedy Barrier
• Sourcing Executive Termination Payments: Analyzing the Bifurcated Sourcing of Severance and RSUs in the Appeal of Otting
• The Permanent Section 45S Paid Family and Medical Leave Credit: Analyzing the Statutory Wage Method Mechanics and the New Premium Method Under Notice 2026-28
• The Tax Court Open Door: Why the BBA Partnership Petition Deadline Is Not Jurisdictional
• Commingled Funds, Unsubstantiated Deductions, and the Binding Form of Transactions: A Technical Tax Analysis of Reed v. Commissioner
• The Safe Harbor That Wasn't: Deconstructing the Anti-Abuse Rule in SIH Partners LLLP v. Commissioner
• The Evolution of Qualified Overtime Compensation Deductions: Analyzing IRS Fact Sheet FS-2026-13 and Its Practical Implications

This week we look at:

• IRS Reinstates Tax Deferral on Variable Annuity Term Certain Options: Reconsideration and Reversal in PLR 202630002
• Understanding the ERC Pleading Standard: Federal Claims Court Deferral in I Health and Life Insurance Services
• Predecessor Losses, the Lonely Parent Rule, and the Limits of Economic Reality: Analysis of HBM Holdings Co. v. Commissioner
• Double Books and Disguised Payees: Corporate Personal Expenses and the Civil Fraud Penalty in Prezioso v. Commissioner