This week we look at: Form 1041-A Relief for Passthrough Charitable Deductions (REG-109082-25) Vested Development Rights & Easement Valuation — Malibu Valley Land v. Commissioner First Circuit Bars Equitable Tolling of Section 6213(a) — Kyick Holdings v. Commissioner PRWORA Immigration Restrictions on Refundable Credits (REG-119882-25) Single-Employer DB Pension Funding Proposed Regulations (REG-107855-25) Excluded Property Sales Income Under Section 250 (REG-117130-25) Section 163(j) Business Interest Limitation Update — Fact Sheet FS-2026-14 Doug LaMalfa Federal Disaster Tax Relief Certainty
This week we look at: Unpacking the Saver’s Match: Technical Guidance and Operational Frameworks Under Notice 2026-48 Harmonizing Section 3406 Backup Withholding with Section 6050W De Minimis Reporting Thresholds The High Bar for Equitable Tolling in Tax Practice: The Eighth Circuit’s Final Ruling in Boechler, P.C. Employer Contributions to Trump Accounts and Nondiscrimination Rules under REG-101355-26 The Perpetual Burden of Carryover Substantiation: AMT Credits and Recordkeeping in Beacom v. Commissioner Equitable Tolling of Tax Court Filing Deadlines: Maniktala v. Commissioner (8th Cir.) St
This week we look at: Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4) Trustee-to-Trustee Transfers of Inherited IRAs Through an Estate: Technical Analysis of PLR 202631001 Federal Courts Lack APA Jurisdiction Over Foreign Gift Penalty Disputes: The Adequate Alternative Remedy Barrier Sourcing Executive Termination Payments: Analyzing the Bifurcated Sourcing of Severance and RSUs in the Appeal of Otting The Permanent Section 45S Paid Family and Medical Leave Credit: Analyzing the Statutory Wage Method Mechanics and the New Premi
This week we look at: IRS Reinstates Tax Deferral on Variable Annuity Term Certain Options: Reconsideration and Reversal in PLR 202630002 Understanding the ERC Pleading Standard: Federal Claims Court Deferral in I Health and Life Insurance Services Predecessor Losses, the Lonely Parent Rule, and the Limits of Economic Reality: Analysis of HBM Holdings Co. v. Commissioner Double Books and Disguised Payees: Corporate Personal Expenses and the Civil Fraud Penalty in Prezioso v. Commissioner An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-08-03 On Again Off
This week we look at: Valuation of Remainder Interest Gifts Upon Trust Termination: State Law and Net Gift Adjustments in Lewis v. Commissioner Revenue Procedure 2026-26: Technical Overview of 2027 Indexing Adjustments for Premium Tax Credits and Affordability Standards Limitations of Interest Abatement Claims Under I.R.C. § 6404(e)(1) in the Context of ERC-Driven Amendments Section 6015(c) Relief and the Substantiation Trap: An Analysis of Anderson v. Commissioner Navigating the AICPA’s New Tax Services Independence Standards: A Guide for Practitioners An audio only version of this week’s bro
This week we look at: Partnership Recourse Rules: Conditional DROs will not establish EROL under § 1.752-2. Mileage Rate Adjustment: Business standard mileage rate rises to 76 cents on July 1, 2026. Business Tax Account: Modernized self-service portal expands features but requires active annual maintenance. Litigation Legal Fees: FCRA settlements are taxable gross income without above-the-line deduction. Corporate Reorganizations: Tax Court invalidates regulation limiting 100% DRD in post-Loper Bright era. ERC Litigation Realities: Exhaustion loophole rejected; notice pleading standards approv
This week we look at: Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP) Strict Enforcement of Tax Refund Statutes of Limitations Employee Retention Credit (ERC) Refund Claims & Pleading Standards Pandemic-Era Persistence of New York's Convenience of the Employer Rule Invalidity of Treasury Regulation Section 1.951A-2(c)(5) Non-Shareholder Capital Contributions vs. Compensation Final Section 1035 Exchange & Corporate Reorganization Regulations Reclassification of Abusive CRAT Structures as Listed Transactions The National Taxpayer Advocate’s Perspective on AEP
This week we look at: Relief from Ineffective S Corporation and QSub Elections Procedural and Jurisdictional Limits in Challenging IRS Guidance Medicaid Gross Receipts, Cohan Estimations, and Professional Reliance Standards and Deceit in Supervised Release Transitional Guidance on Qualified Opportunity Zones An audio version of this week’s broadcast can be downloaded or streamed below: 2026-06-22 Qualified Opportunity Zone Interim Guidance for OBBBA Edward K. Zollars, CPA (Arizona) Download Articles for this week’s broadcast and copies of slides can be downloaded below: Current Federal Tax Dev
This week we look at: Section 7508A(d) and Interest on Pre-COVID-19 Disaster Tax Deficiencies The Soroban Capital Partners SECA Tax Controversy Pleading Requirements for the Employee Retention Credit (Tapestry Senior Housing) ERC Causation and the Essential Business Hurdle (RAAM Construction) The Section 530A Transfer Tax Safe Harbor (Rev. Proc. 2026-25) Penalty Supervisory Approval Verification in CDP (Besicorp Group) Retroactive ERC Deadlines & Constitutional Challenges An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-07-06 ERC Cases Galore Week Edward
This week we look at; Nominal S Corporation Ownership and the Abuse Exception Recapping the ERC via Section 7405 Civil Actions Constructive Dividends, Formalities, and Civil Fraud CDP Hearings, Offer-In-Compromise, and RCP Calculations Professional Responsibility and Responsible AI Use Rigorous Proof for ERC "Partial Suspension" Claims An audio only version of this week’s broadcast can be downloaded or streamed below. 2026-06-29 OPR Releases Guidance on Use of Generative AI Edward K. Zollars, CPA (Arizona) Download PDFs with this week’s articles on the updates and the slides used for this week
A discussion of the impact of new Section 68 on trusts and the JCT's Blue Book Footnote 102, IRS previews upcoming Section 25F credit guidance and more.
Two decisions on the ERC and what is a partial suspension completely disagree on the level of causation that must be shown related to a government order, yet another conservation easement taxpayer loss and more.
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) An audio only version of this week’s update can be streamed or downloaded below. 2026-06-01 More Details on the Activation of Trump Accounts Edward K. Zollars, CPA (Arizona) Download PDFs with the slides and this week’s articles can be downloaded via the links below: 2026-06-01 Current Federal Tax Developments Slides
IRS (barely) acquiesces in case of Abdo but will appeal Kwong, House passes an bill to reverse Supreme Court's Zuch decision and more.
Failure to follow CWA rules eliminate all of a charitable contribution deduction, IRS announces syndicated conservation easement settlement initiative, and more.
Yet another syndicated conservation easement taxpayer loss in Tax Court, the FTB loses an attempt to tax an out of state physician and more.
Treasury and IRS previews medical marijuana Section 280E guidance upcoming, the House passes 9 bipartisan tax bills, ERC statute of limitations extension guidance for refund claims and more
DEA rescthedules state-legal medical marijuana, but recreational cannabis stays on Schedule III (and 280E issues continue for those businesses), Seventh Circuit finds claim of right can be used to exclude income from taxation and more.
IRS releases final regulations on qualified tip income, taxpayer finds that getting no cash from a surrendered life insurance policy doesn't necessarily mean no tax issues and more.
Claim of right issue dooms ability to offset repayment of social security benefits, ERC litigant loses case on appeal and more.
IRS issues proposed regulations on Trump Account and the pilot program and the Tax Court looks it issues with an IRS notice in a BBA case.
Two cases outline failed attempts to attempt to remove the block on access to their passports, auto depreciation limits for 2026 and more.
Another Circuit rules that the IRS does have the authority to assess §6038(b) penalties, delay announced in effective date for SECURE 2.0 RMD regulations and more.
Supreme Court overturns tariffs, IRS released interim guidance on Section 168(n) 100% bonus depreciation for qualified production property and more.
Attorney called out for suspected AI hallucinated cases by the Tax Court, First Circuit may be considering a method to avoid ruling on SE status or limited partners and more.
