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

This week we look at:

• Court Frowns on Professional's Use of Randomly Generated Social Security Numbers
• Understanding the "Placed in Service" Rule for Electric Vehicle Credits
• Advisers Found to Owe Treble Damages to Impacted Taxpayers
• W-2 Wages and the Qualified Business Income Deduction Under Section 280E
• Trust Fund Recovery Penalties and Refund Claim Timeliness in Richter v. The United States

This week we look at:

• Eleventh Circuit: Gross Valuation Misstatement Penalty in a Conservation Easement Case
• Treasury & IRS: Preliminary Guidance on Tipped Occupations
• Eighth Circuit: Medtronic Transfer Pricing Dispute Remanded Again
• California OTA: Entertainer Found to be a California Resident
• Pitfalls in IRA Bankruptcy Exemptions: Farber v. Feldman

This week we look at:

• Federal Circuit Ruling Finds Limits on Executive Authority to Impose Tariffs Under IEEPA
• Introduction to OBBBA R&E Expenditure Procedures
• Sixth Circuit Realigns on Tax Court Jurisdiction
• Innocent Spouse Relief: Walsh v. Commissioner Overview
• Taxpayer Precluded from Challenging Liability: Sullivan v. Commissioner
• 60-Day IRA Rollover Waiver in a Fraud Scenario