In the recent decision of Alioto v. Commissioner, T.C. Memo. 2025-125, the United States Tax Court addressed the consequences of a taxpayer failing to respect the separate existence of his closely held corporation. The Court ruled in favor of the Commissioner regarding deficiencies stemming from unreported wage income, constructive dividends, and capital gains, while simultaneously disallowing personal deductions for corporate business expenses. For tax professionals, this case serves as a stark reminder of the rigorous substantiation requirements for accountable plans and the application of the "duty of consistency" in preventing taxpayers from taking contrary positions to those of their controlled entities.

The Internal Revenue Service has released a draft version of Form 4547, Trump Account Election(s), scheduled for release in December 2025. This form facilitates the election to establish a "Trump Account"—statutorily defined as a type of traditional individual retirement account (IRA) subject to distinct regulatory modifications during a designated "growth period". For tax professionals preparing for the 2025 tax season and beyond, understanding the specific elections, contribution limits, and filing procedures associated with this new instrument is essential.

The Department of the Treasury and the Internal Revenue Service (IRS) have issued Notice 2025-68 to provide preliminary guidance on Section 70204 of the "One, Big, Beautiful Bill Act" (OBBBA), Public Law 119-21. This legislation introduces Section 530A, establishing "Trump accounts," and Section 6434, creating a pilot program for government contributions. The provisions generally apply to taxable years beginning after December 31, 2025.

For tax professionals, this Notice outlines a bifurcated retirement vehicle that operates under unique strictures during a beneficiary’s minority (the "growth period") before converting to standard Traditional IRA rules upon the beneficiary attaining age 18.

The U.S. Tax Court, in Lake Jordan Holdings, LLC v. Commissioner, T.C. Memo. 2025-123, delivered a thorough rejection of an egregious valuation claimed for a syndicated conservation easement, underscoring the necessity of grounding valuations in objective market realities rather than speculative assumptions. This memorandum opinion details the continuation of the "depressingly long line" of cash grabs disguised as charitable contributions. Although the Court ultimately found the basic requirements for claiming a charitable contribution deduction were met, the value claimed was deemed excessive, leading to the imposition of a 40% gross valuation misstatement penalty.

The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) announced their intent to issue forthcoming proposed regulations to implement the new individual tax credit provision codified as § 25F of the Internal Revenue Code (Code). This section was added by § 70411 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA).

Notice 2025-70 requests comments regarding issues arising under § 25F, emphasizing those issues related to the annual certification by a State and Scholarship Granting Organization (SGO) requirements, where prompt guidance is needed. The Secretary is directed by § 25F(h) to issue regulations or other guidance deemed necessary to carry out the purposes of § 25F, including guidance for enforcement and recordkeeping/information reporting.

The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued Notice 2025-72 to announce their intent to issue forthcoming proposed regulations addressing two key areas impacted by recent legislation. Specifically, the notice details plans for proposed regulations under Section 70352 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), which repealed Section 898(c)(2) of the Internal Revenue Code (Code). The OBBBA directed the Treasury Department and the IRS to issue guidance on allocating foreign taxes for foreign corporations affected by this repeal (the forthcoming proposed Section 898 regulations). Additionally, the notice addresses forthcoming proposed regulations under Section 987 that will modify the election concerning the recognition of pretransition Section 987 gain or loss ratably over the transition period pursuant to §1.987-10(e)(5)(ii)(A).

This article examines the decision of the United States Court of Federal Claims in Quinones v. United States, No. 24-810 (Fed. Cl. Nov. 21, 2025), focusing on the government’s successful recovery of an erroneously issued tax refund based on fraudulent reporting practices. The memorandum order and opinion issued by Judge Tapp provides crucial clarity regarding the application of the erroneous refund recovery standard and the weight accorded to fraudulent taxpayer representations under the self-assessment system.

This supplemental memorandum opinion addresses a taxpayer’s motion for reconsideration regarding the application and validity of Treasury Regulations governing the deduction of losses from activities not engaged in for profit, specifically in the wake of the Supreme Court’s ruling in Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024). This analysis focuses on whether Tecomate Industries, LLC (TI), a partnership, engaged in its farming activity with the requisite profit motive under Internal Revenue Code (I.R.C.) § 183.

On November 21, 2025, the Department of the Treasury and the Internal Revenue Service (IRS) jointly issued Notice 2025-69, providing crucial guidance for individual taxpayers eligible to claim new federal income tax deductions for qualified tips and qualified overtime compensation for the 2025 tax year. These new provisions were introduced by Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly referred to as the One, Big, Beautiful Bill Act (OBBBA).

The OBBBA added new Code Section 224, granting an income tax deduction for "qualified tips," and new Code Section 225, granting an income tax deduction for "qualified overtime compensation". Both deductions are available for tax years beginning after December 31, 2024, and ending before January 1, 2029. The IRS is currently updating income tax forms and instructions to facilitate the claiming of these deductions during the filing season.

The Treasury Department and the IRS have finalized regulations (TD 10037) providing definitive guidance on the application of the stock repurchase excise tax, enacted under section 10201 of the Inflation Reduction Act of 2022 (IRA). These final regulations, which amend 26 CFR parts 1 and 58, are effective on November 24, 2025. They affect domestic publicly traded corporations and their specified affiliates for repurchases made after December 31, 2022. This technical guidance is issued pursuant to the express delegations of authority found in sections 1275(d), 4501(f), and 7805(a) of the Code.

The enactment of section 139L of the Internal Revenue Code (Code) by Public Law 119-21, 139 Stat. 72 (July 4, 2025), known as the One, Big, Beautiful Bill Act (OBBBA), created a new partial exclusion from gross income for certain interest received by qualified lenders. Notice 2025-71 has been issued by the Treasury Department and the Internal Revenue Service (IRS) to provide crucial interim guidance on the application of this provision. This article outlines the statutory requirements, details the administrative positions provided in the Notice, and clarifies the reliance standards for tax professionals advising qualified lenders.

This article examines the decision in United States of America v. Tuncay Saydam, Case No. 22-cv-07371-DMR, issued by the United States District Court for the Northern District of California. The case centers on the application of the Excessive Fines Clause of the Eighth Amendment to willful civil penalties imposed for failure to file Reports of Foreign Bank and Financial Accounts (FBARs).

This article examines the decision in Tom Prescott v. Commissioner of Internal Revenue, T.C. Memo. 2025-121 (2025), focusing on the technical requirements for establishing a mandatory whistleblower award under Internal Revenue Code (I.R.C.) section 7623(b) and the corresponding Treasury Regulations. The case hinges on whether the information provided by the petitioner "substantially contributed" to the resulting administrative action and collection of proceeds, especially in the context of multiple independent whistleblower claims.

This article examines the recent Tax Court Memorandum decision in John DiTullio v. Commissioner of Internal Revenue, T.C. Memo. 2025-120, concerning the critical requirement under pre-Tax Cuts and Jobs Act (TCJA) law that alimony payments terminate upon the death of the payee spouse to qualify for a deduction under Section 215(a). This case highlights the necessity of explicit termination provisions, especially where state law regarding maintenance obligations is deemed ambiguous.

On November 14, 2025, the Centers for Medicare & Medicaid Services (CMS) released the finalized amounts for premiums, deductibles, and coinsurance under the Medicare Part A and Part B programs for the 2026 calendar year, concurrently announcing the Medicare Part D income-related monthly adjustment amounts (IRMAA). This technical brief reviews the statutory context and the specific figures relevant to client planning for 2026, focusing particularly on the impact of modified adjusted gross income (MAGI) thresholds on Part B and Part D premiums.

The recent decision in Jodell Sample v. Commissioner of Internal Revenue, T.C. Memo. 2025-118, presents a complex application of Internal Revenue Code (I.R.C.) § 6015, particularly concerning the interaction of knowledge standards across subsections (b), (c), and (f) relief, and the critical role of the administrative record in a stipulated Tax Court case. This analysis details the facts, the scope of the taxpayer’s requests for relief from joint and several liability, and the court’s strict application of statutory and procedural standards.

The case, Apache Corporation and Subsidiaries v. Commissioner of Internal Revenue, 165 T.C. No. 11 (2025), addressed a critical issue concerning the elective relinquishment of net operating loss (NOL) carryback periods under I.R.C. § 172.

The Internal Revenue Service (IRS) issued Notice 2025-67 to announce the cost-of-living adjustments (COLAs) that will take effect on January 1, 2026, for the limitations pertaining to qualified retirement plans and Individual Retirement Arrangements (IRAs). This guidance is essential for tax professionals and plan administrators to determine the correct compliance thresholds and maximum contribution levels for the upcoming plan year.

The United States Tax Court, in Pascucci v. Commissioner, T.C. Memo. 2024-43 (Apr. 15, 2024), and subsequently the United States Court of Appeals for the Second Circuit in Pascucci v. Commissioner of Internal Revenue, No. 24-2429 (2d Cir. Nov. 12, 2025) (Summary Order), addressed the critical question of property ownership in the context of a claimed theft loss deduction stemming from the Bernard L. Madoff Ponzi scheme. The courts determined that indirect investors in variable life insurance policies, though victims of the underlying fraud, lacked the requisite property interest in the stolen funds necessary to sustain a deduction under I.R.C. § 165(c)(3).

Updated November 13 to add discussion of threshold relevancy determination.

The United States Tax Court, in Sunil S. Patel and Laurie McAnally Patel, et al. v. Commissioner of Internal Revenue, 165 T.C. No. 10 (2025), addressed the imposition of accuracy-related penalties following its determination in Patel v. Commissioner, T.C. Memo. 2024-34 (Patel II), that amounts paid to purported captive insurance companies Magellan and Plymouth, and to the reinsurer Capstone Reinsurance Co., Ltd. (Capstone), were not insurance premiums for federal income tax purposes. This Opinion specifically resolves the remaining issue: whether Petitioners (Ps) are liable for various accuracy-related penalties under I.R.C. § 6662(a), including penalties predicated on the codified economic substance doctrine under I.R.C. § 7701(o). The relevant tax years at issue are 2013, 2014, 2015, and 2016.