Federal Tax Update Podcast

This week we look at: Understanding Automatic Accounting Method Changes-Revenue Procedure 2025-23 Accounting Method Changes in Conmac Investments, Inc. Conservation Easements in Glade Creek Partners, LLC Tax Treaty Exemptions in Kramarenko v. Commissioner Tax Refund Litigation & Variance Doctrine in Shleifer v. U.S. Tax Court Jurisdiction in Commissioner v. Zuch Digital Asset Reporting & Withholdi...

This week we look at: Navigating Corporate Alternative Minimum Tax (CAMT) Conservation Easement Valuation & Penalties: A Warning from Tax Court Collection Due Process (CDP) & Offers in Compromise (OICs): Lessons from Tax Court Accuracy-Related Penalties: Navigating Negligence and Insufficient Professional Reliance Understanding Treasury's Request for Information on Modernizing Federal Payments Wor...

This week we look at: Self-Employment Tax for Limited Partners ( Soroban II ) Presidential Tariffs Under IEEPA (USCIT Decision & Federal Circuit Stay) Massachusetts Source Income (Welch Case Petition) Foreign Gift Penalties (Huang Case)  

This week we look at: IRS Reduces Estate Tax Closing Letter Fee Tax Court Scope of Review in Passport Cases Marital Deduction for Bequests to Trust "Reasonable Cause" in Late-Filing Penalty Cases "No Tax on Tips Act" (S.129) Passes Senate Transfer Pricing in Facebook, Inc. & Subsidiaries v. Commissioner Navigating New York's Convenience Rule: Insights from Matter of Zelinsky

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 Di...

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 S...

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...

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

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 s...

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...

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 Reve...

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 Pr...

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...

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 h...

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...

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

This week we look at: IRS announces program using IP-PIN to allow taxpayers who find a dependent on their return has already been listed on another to get their return processed immediately The ERC Second Voluntary Disclosure Program ends but the IRS gives some additional relief for withdrawing a claim filed via third-party payer such as a payroll service