Federal Tax Update Podcast

This week we look at:

• Proposed Increase to Estate Tax Closing Letter User Fee
• Divergent Causation Standards for ERC Eligibility
• Valuation Extremes in Conservation Easements
• Substantiating Mortgage Interest Deductions
• Taxation of Cryptocurrency Staking Rewards
• Section 4960 and "Covered Employees"
• FBAR Compliance and IRS Agent Authority

This week we look at:

• Procedural Timeliness & Automatic Extensions

• Spousal IRA Rollovers Through Estates and Trusts

• Collateral Estoppel and the "Innocent" Spouse

• Improper Corporate Deductions and Fraud

• Implementation of "Trump Accounts"

• 2027 Inflation Adjustments (HSA, HRA, DPCSA)

This week we look at:

• Equitable Relief for Erroneous Tax Refunds: An Analysis of the Fourth Circuit's Reversal in LaRosa v. Commissioner

• Final Regulations Modify Information Reporting for Section 751(a) Partnership Interest Exchanges

• The Impermeable Reach of Section 6672: Joint and Several Trust Fund Liability and the Demise of the Delegation Defense

• The Taxpayer Due Process Enhancement Act (H.R. 6506): A Crucial Legislative Response to Commissioner v. Zuch

• Demystifying Notice 2026-33: Comprehensive Guidance on Qualified Long-Term Care Distributions under the SECURE 2.0 Act

• IRS Action on Decision: Decoding the Service's Limited Acquiescence on Mandatory COVID-19 Postponements and the Road Ahead in Kwong

This week we look at:

• Technical Analysis of the Proposed Regulations Establishing Excepted Fertility Benefits
• Analysis of the IRS Time-Limited Settlement Initiative for Conservation Easement Disputes
• Strict Compliance with Contemporaneous Written Acknowledgment Requirements in Charitable Land Contributions
• Transferee Tax Liability and the Consequences of Willful Blindness: An Analysis of Dillon Trust Company v. United States

This week we look at:

• Syndicated Conservation Easements and the Valuation Conundrum: An Analysis of T.C. Memo. 2026-36
• Analysis of Garcia-Rojas v. Franchise Tax Board: The Limits of the Unitary Business Doctrine for Sole Proprietors
• An Analysis of the Reinstated Significant Issue Letter Ruling Program Under Revenue Procedure 2026-21
• The "Byers Rule" and the Administrative Procedure Act
• Jurisdictional Time Bars and the Timely Mailing Rule: An Analysis of Dunlap v. United States
• Temporary Import Surcharges and Executive Authority: A Review of the Court of International Trade's Ruling

This week we look at:

• Reasonable Cause Relief Under the Small-Corporation Provision for Form 5472 Penalties
• Extending the Statute of Limitations for Disallowed ERC Claims
• Legislative Update: House Passes Comprehensive Tax Administration and Relief Bills
• Anticipated IRS Guidance Following the Rescheduling of Medical Marijuana
• Analysis of the New Dyed Fuel Excise Tax Refund Regulations Under Section 6435
• Executive Order on Retirement Savings and Its Interaction with IRC Section 6433

This week we look at:

• Tax Implications of the Rescheduling of State-Licensed Medical Marijuana
• Disallowance of COVID-19 Leave Credits: A Review of Substantiation and Trade or Business Requirements
• The Tenth Circuit Codifies the Reach of the Economic Substance Doctrine Over Mechanical Statutory Compliance
• Substantiation, Entity Indebtedness, and Business Expense Deductibility: An Analysis of the Simmons Case
• Treatment of Loyalty Rewards Program Funds and the Claim of Right Doctrine
• Valuation and Penalty Controversies in Estate Tax Examinations

This week we look at:

• A Technical Analysis of the Final Section 224 Regulations on the Qualified Tip Deduction

• Analysis of Proposed Regulations on Information Reporting Thresholds and Wagering Losses (REG-113229-25)

• U.S. District Court Splits Its Ruling on Micro-Captive Disclosure Mandates

• IRS Reduces Enrolled Agent Special Enrollment Examination User Fees: An Analysis of the Interim Final and Proposed Regulations

• Taxation of Terminated Life Insurance Policies: An Analysis of Constructive Receipt and Investment Interest

This week we look at:

• Corporate Capacity and State Law Revivor

• Digital Asset Identification Relief

• Interest and Bonus Depreciation Relief

• ERC Disallowances and Legal Standing

• Substantiation Rules for Emergency Vehicles

• Partnership Audits and Due Process

• Social Security Repayments

This week we look at:

• Proposed Regulations for IRC Section 530A "Trump Accounts"
• IRC Section 6434 Trump Account Pilot Program
• Micro-Captive Scrutiny Formalized
• BBA Audits: Notice Defects and the Statute of Limitations