Federal Tax Update Podcast

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

This week we look at:

• Federal Complaint Seeking ERC Refunds: Superior Pediatric Care v. United States
• Proposed Revisions to Partnership Information Reporting for Sales or Exchanges of Interests—Form 8308
• Taxation of Unsolicited Stock Transfers: Analysis of Feige v. Commissioner
• Third-Party Intent and the Indefinite Assessment Period: An Analysis of Murrin v. Commissioner
• The One, Big, Beautiful Bill Act (OBBBA): New Deductions & Energy Credit Modifications
• LLM Limitations in Tax Law: Beyond Memorization

This week we look at:

• Denham Outlines Its Criticisms of the Tax Court's Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals
• Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner
• Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility
• The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners
• Understanding New Clean Electricity Credit Termination Rules Impact of IRS Notice 2025-42 on Wind and Solar Facilities

This week we look at:

• Urgent Guidance Requested on Section 174A Domestic Research and Experimental Expenditures
• Post-Referral Authority in Tax Litigation—IRS Lacked Authority to Approve ERC Refund
• Closer This Time, But Still Not Quite There—Another Microcaptive Loss for the Taxpayers
• Proposed Amendments to IRC Section 132 Fringe Benefit Rules: Switching to NAICS
• Understanding Passthrough Losses and Bankruptcy in Field Attorney Advice 20253101F
• Proactive Engagement with the Office of Professional Responsibility
• IRS Announces Policy for the One Big Beautiful Bill Act for 2025 Payroll Issues

This week we look at:

• Filing Season Forecast to Start in Mid-February in the Coming Season
• Settlement Proceeds Found to Be Taxable and Taxpayer Stuck With Late-Filing Penalties
• IRS Issues Relief for Certain Issues Related to Partnership Investments and the Corporate Alternative Minimum Tax
• Corporate Mergers and the Same Taxpayer Rule for Interest Netting
• What Is an Educational Organization for Unrelated Business Income Tax (UBIT) Purposes?
• Another Microcaptive Arrangement Falls Under Court Challenge
• Taxpayer's Claim She Didn't Consent to the Filing of a Joint Return Didn't Impact Denial of Innocent Spouse Relief