Federal Tax Update Podcast

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

This week we look at:

• Tax Court Finds Taxpayer Failed to Provide a Qualified Appraisal, No Charitable Deduction Allowed
• Estate Found Liable for $2 Million FBAR Penalty That Applied to the Decedent
• Taxpayers Filing Court Challenges to Attempt to Obtain Employee Retention Tax Credits
• Fourth Circuit Overturns Trial Court's Grant of Summary Judgment to the Government, Finding True Issue of Fact Exists Regarding Whether Statute Remained Open
• IRS Memorandum Discusses When a Taxpayer Can Claim a Deduction as Victims of Various Scams Under Current Law

This week we look at:

• Treasury and the Corporate Transparency Act (BOI Reporting)
• Martino v. Commissioner: Alimony Deduction Case
• Estate of Kalikow v. Commissioner: Estate Tax & Settlement Payments
• Appeal of A. Markowski: California Source Income for Nonresidents
• CF Headquarters Corporation v. Commissioner: Taxability of Grants
• United States v. Gora: IRS Levy Enforcement

This week we look at:

• FinCEN Announcement on BOI Reporting Penalties
• Tax Court Case: Alan Hamel and Estate of Suzanne Hamel v. Commissioner
• IRS "Dirty Dozen" Tax Scams for 2025
• IRS Adds Tax Documents to Online Accounts
• Ways and Means Committee Passes Disaster Relief Bills
• House and Senate Budget Resolutions

This week we look at:

• Second Circuit Rules on Section 179D Deductions and Accounting Method Change
• IRS Guidance on ACA Notice Posting
• Court Case on CPA Negligence and Trust Return Penalties
• BOI Reporting Requirement Updates

This week we look at:

• Deductibility of Losses: Weston v. Commissioner
• Conservation Easements: Green Valley Investors LLC
• Automobile Depreciation and Lease Inclusion
• S Corporation Inadvertent Termination Relief
• Corporate Transparency Act (CTA) - Government Briefs
• House Ways & Means Committee Tax Bills