Federal Tax Update Podcast

This week we look at:

• IRS issues letter ruling on IRA left to trust
• A taxpayer mistakenly believes the IRS had conceded that his income was not subject to self-employment tax, but it hadn't
• The Tax Court denies a taxpayer's deductions and claimed partnership losses due to incredibly disorganized and inadequate records
• Taxpayer runs afoul of the "pay first, litigate later" rule when attempting to sue the IRS for a refund in US District Court in response to an assessment
• A taxpayer's unprocessed claim for an ERTC refund doesn't justify CDP relief
• The BOI - new Administration continues litigation and proposes a new due date, potential filing relief

This week we look at:

• Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on Return
• IRS Finds Most Expenses Related to Taxpayers' In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213
• Taxpayer Denied Innocent Spouse Relief in Tax Court Bench Opinion
• Tax Court Finds No Issue With the Appeals Office Structure and Staffing
• Failure to Provide Proof of Filing of Returns Fatal to Taxpayer's Attempt at Obtaining Relief in CDP Hearing Despite IRS Procedural Errors

This week we look at:

• Funds Taken By Sheriff Were a Valid Loan and Not Income from Embezzlement
• Tax Court Allows a Reduced Deduction for a Conservation Easement
• CCA Discusses Issues with Activities of a Private Foundation with Regard to Self-Dealing, Attempted Correction and Jeopardizing Investments
• IRS Email Discusses Agency's (Lack of) Obligation to Process Amended Tax Returns
• Supreme Court Reverses Fifth Circuit Merits Panel, Again Removes Emergency Injunction Against Enforcement of the CTA
• BOI Reports Despite Supreme Court's Action on Texas Top Cop Shop, Inc. Ban on Enforcement of BOI Reporting, FinCEN Notes Ban on Enforcement Under the Smith Case is Still in Effect

This week we look at:

• IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 property
• Proposed regulations on catch-up contributions added by the SECURE 2.0 Act
• Proposed regulations on the automatic enrollment provisions of IRC §414A
• US Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process case
• IRS issues final regulations on resolution of tax controversies by the IRS Independent Office of Appeals Under TFA of 2019

This week we look at:

• IRS Grants Tax Relief to California Wildfire Victims
• National Taxpayer Advocate's Report to Congress and Legislative Recommendations Released
• Third US District Court Issues BOI Reporting Injunction
• Tax Court Finds a Building Was Not a Certified Historic Structure as Defined by §170(h)
• Taxpayer Denied Refund as Court Found the Taxpayer Had Taken the Position That Its
• Reporting Was an Error Rather Than a Method of Accounting
• Seventh Circuit Upholds Imposition of Fraud Penalty for an Overstatement of Withholdings
• Court Finds Taxpayer Submitted Digitally Altered False Documents, Sustained the Fraud Penalty the IRS Proposed
• IRS Updates Guidance on Section 530 Employment Tax Liability Relief

This week we look at:

• IRS gives relief for specific identification of digital asset basis for certain taxpayers for 2025 only
• Department of Justice asks the U.S. Supreme Court to Stay the Latest Corporate Transparency Act Injunction
• IRS no longer to dispute requirement to comply with APA to add listed transactions after the enactment AJCA in 2024
• Tax Court rules that merely being in a registered historic area does not make a building a certified historic structure
• Tax Court finds taxpayer owes tax on over $5.3 million diverted from two retirement plans

This week we look at:

• Automatic accounting method changes related to §174 extended to years beginning in 2024
• BOI report - hectic week, but ultimately no resolution yet for initial report due date
• 2025 mileage rates published by the IRS
• IRS finalizes regulations on supervisory approval of penalties
• IRS proposes revisions to Circular 230

This week we look at:

• President signs the two tax bills Congress recently passed
• DOJ asks for stay of injunction issued by US District Court in Texas on enforcement of the CTA
• IRS expands Business Tax Account access and services that can be accessed via that account

This week we look at:

• Congress enacts two tax laws: but neither is the big one that passed the House in January but stalled in the US Senate
• A Texas US District Court has issued a nationwide temporary injunction barring FinCEN from enforcing the BOI reporting regime
• DOJ files a notice of Appeal of the Texas Top Cop Shop Inc decision and FinCEN posts information regarding the impact of the case on BOI reports

This week we look at:

• IRS releases optional form taxpayer can use to make an IRC §83(b) election
• IRS extends for one year more a transitional 45-day period to perfect research credit claims found to be invalid claims
• IRS provides additional relief on the issuance of Forms 1099-K