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

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

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

This week we look at:

• Self-Employment Tax for Limited Partners (Soroban II)
• Presidential Tariffs Under IEEPA (USCIT Decision & Federal Circuit Stay)
• Massachusetts Source Income (Welch Case Petition)
• Foreign Gift Penalties (Huang Case)

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

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

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

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

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

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