For United States citizens and residents living and working abroad, I.R.C. § 911 provides a highly valuable tax benefit. Under I.R.C. § 911(a), a "qualified individual" may elect to exclude from gross income their foreign earned income and their housing cost amount. However, to meet the definition of a "qualified individual," a taxpayer must establish that their tax home is in a foreign country and must satisfy one of two stringent time-based tests under I.R.C. § 911(d)(1). They must either be a bona fide resident of a foreign country for an uninterrupted period that includes an entire taxable year, or they must be physically present in a foreign country or countries for at least 330 full days during any period of 12 consecutive months.

Under Internal Revenue Code (IRC) § 7345, the IRS is granted the statutory authority to certify a taxpayer as having a "seriously delinquent tax debt". Once the Secretary of the Treasury transmits this certification, the Secretary of State is mandated to take "action with respect to denial, revocation, or limitation of a passport". The recent United States District Court for the District of Rhode Island decision in United States v. Richard H. Hatch Jr., No. 1:22-cv-00332 (D.R.I. Mar. 2, 2026), highlights the rigid procedural boundaries taxpayers and their representatives face when attempting to challenge a passport revocation in the midst of an active federal tax collection suit.

In Kavan Shaban v. Commissioner of Internal Revenue, T.C. Memo. 2026-24, the taxpayer, Kavan Shaban, is a medical doctor who co-owns a group of family businesses, including Persona Doctors HQ, LLC (PersonaHQ). In 2007, Mr. Shaban hired his brother, Shevan, to serve as the business manager. Shevan’s responsibilities included managing payroll, filing tax returns, and paying payroll taxes. In 2019, Mr. Shaban discovered that Shevan had embezzled approximately $9 million from the family businesses, which included trust fund taxes that were meant to be paid to the Internal Revenue Service (IRS). After Mr. Shaban initiated a civil lawsuit in Maryland state court, Shevan admitted to the embezzlement, acknowledged filing false tax returns, and took sole responsibility for the nonpayment of the trust fund taxes.

Pursuant to I.R.C. § 6672(a), the IRS determined that Mr. Shaban was a responsible person and assessed Trust Fund Recovery Penalties (TFRPs) against him for the periods ending September 30, 2018, June 30, 2019, and December 31, 2019. The TFRPs were officially assessed on September 15, 2023, following an unsuccessful protest by Mr. Shaban’s representative, who failed to timely respond to IRS document requests. To collect the unpaid TFRPs, the IRS issued a Notice of Intent to Levy and a Notice of Federal Tax Lien Filing in November 2023. Mr. Shaban did not request a Collection Due Process (CDP) hearing in response to either notice.

Because the TFRP liabilities remained unpaid, the IRS certified Mr. Shaban to the Department of State as an individual with a "seriously delinquent tax debt" pursuant to I.R.C. § 7345(a). After a temporary reversal due to a submitted Offer in Compromise (OIC) that was subsequently rejected, the IRS issued a Notice of Certification of Your Seriously Delinquent Federal Tax Debt to the U.S. Department of State in March 2025, when Mr. Shaban’s debt totaled $147,274.

For tax professionals advising clients on the acquisition or leasing of business vehicles, Revenue Procedure 2026-15 is the essential annual guidance that updates depreciation limits and lease inclusion amounts. According to the guidance, "This revenue procedure provides: (1) two tables of limitations on depreciation deductions for owners of passenger automobiles placed in service by the taxpayer during calendar year 2026; and (2) a table of dollar amounts that must be used to determine income inclusions by lessees of passenger automobiles with a lease term beginning in calendar year 2026".

For practitioners applying these rules, it is important to note that "the term ‘passenger automobiles’ includes trucks and vans".

For tax professionals advising clients on entity structuring and partnership contributions, the intersection of the "check-the-box" regulations and Subchapter K can present complex, and sometimes unforgiving, traps. The United States Tax Court recently addressed a novel question in this realm in Continental Grand Limited Partnership v. Commissioner, 166 T.C. No. 3 (2026), evaluating how a retroactive entity classification election impacts the basis of a self-issued promissory note contributed to a partnership.

This article details the factual background, the taxpayer’s arguments, the Tax Court’s technical analysis, and the ultimate conclusions that CPAs and EAs must be aware of when navigating entity classification elections and partnership basis rules.

The case of United States v. Monty Karst involves a lawsuit brought by the United States Government against Monty Karst and Todd Alan Templeton in the U.S. District Court for the District of Kansas. Decided by Judge Toby Crouse on February 27, 2026, the court granted summary judgment in favor of the Government to recover unpaid federal estate taxes.

On February 27, 2026, the United States Court of Appeals for the Second Circuit issued a pivotal ruling for tax professionals regarding the Internal Revenue Service’s (IRS) authority to assess foreign reporting penalties. In Safdieh v. Commissioner (No. 25-501-cv), the court held that the Commissioner of Internal Revenue may collect penalties under Internal Revenue Code (I.R.C.) § 6038(b) via administrative assessment. This decision officially aligns the Second Circuit with the D.C. Circuit in affirming the IRS’s administrative collection powers for this specific international information reporting penalty.

In Otay Project LP v. Commissioner, TC Memo 2026-21, the Tax Court denied the taxpayers a $714 million deduction. The court determined that the partnership’s claim for a §743(b) basis adjustment, which was created through a structure the court found to lack economic substance, was invalid.

In a significant ruling for tax practitioners advising clients on Collection Due Process (CDP) proceedings and assessable penalties, the United States Tax Court recently issued an opinion in The Diversified Group Incorporated v. Commissioner and James Haber v. Commissioner, 166 T.C. No. 2 (Filed February 23, 2026). At the core of the Commissioner’s Motion for Partial Summary Judgment was whether the taxpayers could challenge massive I.R.C. § 6707 penalties during a CDP hearing after previously refusing to participate in an IRS Appeals conference. Judge Toro’s opinion provides critical guidance on I.R.C. § 6330(c)(2)(B) preclusion, the survival of Treasury Regulations post-Loper Bright, and the applicability of the Chenery doctrine in de novo Tax Court proceedings.

The regulatory landscape governing required minimum distributions (RMDs) continues to shift as the Department of the Treasury and the Internal Revenue Service (IRS) process industry feedback regarding the integration of the SECURE 2.0 Act into the tax code. In July 2024, the IRS published extensive proposed regulations in the Federal Register to address changes stemming from the SECURE 2.0 Act, generally proposing an applicability date of January 1, 2025.

However, following a public comment period and a public hearing, the IRS issued Announcement 2026-7 to formally delay the applicability date for specific, highly technical sections of these proposed regulations. For CPAs and tax practitioners advising plan administrators and individual taxpayers, understanding the rationale behind this delay, the relief it provides, and the underlying regulatory provisions impacted is essential for maintaining compliance.

The Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2026-16 to provide crucial administrative guidance regarding the new temporary special depreciation allowance. The primary reason the IRS has issued this notice is to announce that the Treasury Department and the IRS "intend to issue proposed regulations (forthcoming proposed regulations) addressing the special depreciation allowance for qualified production property under § 168(n) of the Internal Revenue Code (Code)".

Because the enactment of the One, Big, Beautiful Bill Act (OBBBA) significantly altered depreciation timelines for certain property, tax professionals require immediate operational rules. Notice 2026-16 bridges the gap between the statutory enactment and the eventual publication of final Treasury Regulations by offering interim guidance upon which taxpayers may rely.

In a highly consequential ruling for tax professionals, trade advisors, and their clients, the Supreme Court of the United States issued its decision in the consolidated cases of Learning Resources, Inc. v. Trump and Trump v. V.O.S. Selections, Inc.. The core issue before the Court was whether the International Emergency Economic Powers Act (IEEPA) authorizes the President of the United States to impose tariffs.

For tax professionals representing partnerships or investors in syndicated conservation easements (SCEs), the United States Tax Court’s recent memorandum decision in North Donald LA Property, LLC v. Commissioner, T.C. Memo. 2026-19, provides essential guidance. The case touches upon the rigorous requirements for qualified appraisals, the critical determination of a property’s highest and best use (HBU) for valuation, the deductibility of syndication costs, and the nuanced application of civil fraud and gross valuation misstatement penalties. This article outlines the factual background, the taxpayer’s positions, the Court’s technical analysis of the applicable Internal Revenue Code (I.R.C.) provisions, and the final conclusions.

The foundational rule of tax administration is repose: typically, the Internal Revenue Service (IRS) must assess tax within three years of a return’s filing under Internal Revenue Code (IRC) Section 6501(a). However, a recent precedential decision by the Third Circuit Court of Appeals in Murrin v. Commissioner, 158 F.4th 527 (3d Cir. 2025), has deepened a critical circuit split regarding the fraud exception to this rule.

On February 17, 2026, the taxpayer filed a Petition for a Writ of Certiorari with the U.S. Supreme Court. The petition asks the Court to decide a binary but high-stakes question: Does the "false or fraudulent return" exception to the statute of limitations apply when the fraud is committed solely by a third-party preparer without the taxpayer’s knowledge or intent?

This article analyzes the Third Circuit’s decision, the conflicting precedent from the Federal Circuit in BASR Partnership, and the arguments presented in the taxpayer’s petition for review.

Notice 2026-7 provides "additional interim guidance regarding the application of the corporate alternative minimum tax (CAMT) under §§ 55, 56A, and 59 of the Internal Revenue Code (Code)". Following the release of the CAMT Proposed Regulations and subsequent notices, the Treasury Department and the Internal Revenue Service (IRS) received numerous comments from tax professionals and stakeholders. Commenters highlighted specific situations where rigid adherence to financial statement income (FSI) without corresponding adjustments would result in severe compliance burdens, artificial acceleration of CAMT liabilities, and potential discouragement of domestic investment.

Relying on the authority granted under § 56A(c)(15), which allows the Secretary "to issue regulations or other guidance to provide for such adjustments to AFSI as the Secretary determines necessary to carry out the purposes of § 56A, including adjustments to prevent the omission or duplication of any item," the IRS issued this Notice to provide specific technical adjustments to Adjusted Financial Statement Income (AFSI).

In the realm of consolidated corporate returns, the distinction between a mere clerical error and a fundamental defect can determine whether a district court possesses subject matter jurisdiction over a refund suit. In the recent decision of American Guardian Holdings, Inc. v. United States, the U.S. District Court for the Northern District of Illinois dismissed a refund claim under Federal Rule of Civil Procedure 12(b)(1). The court held that an amended return that fails to comport with consolidated return regulations, lacks required supporting schedules, and contains signature defects is not "duly filed," thereby depriving the court of jurisdiction.

The Tax Court’s recent memorandum opinion in Goodwill-Oikerhe v. Commissioner, T.C. Memo. 2026-18, serves as a stark reminder of the rigorous substantiation standards required to support deductions and the severe consequences of failing to meet them. The case involves a petitioner who was not only a taxpayer but a "highly educated individual" with a master’s degree in accounting and a professional tax return preparer.

The Court sustained the IRS’s disallowance of numerous personal and business deductions and, notably, upheld the imposition of Section 6663 civil fraud penalties. For tax professionals, this opinion reinforces the critical importance of maintaining adequate records and the futility of "implausible or inconsistent explanations" when facing examination.

For tax professionals representing clients in deficiency proceedings, the distinction between a rebate refund and a nonrebate refund is more than a semantic difference; it is a jurisdictional pivot point that determines whether the IRS may utilize deficiency procedures or must file a suit for erroneous refund. In the recent case of El v. Commissioner, T.C. Memo. 2026-17, the United States Tax Court addressed whether a massive refund generated by an IRS computer error constituted a rebate or a nonrebate refund. The Court’s analysis provides critical guidance on how Section 6211 defines a deficiency, particularly involving refundable credits and automated processing errors.

The interaction between bankruptcy proceedings and tax liability often creates complex evidentiary records. In Veeraswamy v. Comm’r of Internal Revenue, the United States Court of Appeals for the Second Circuit addressed a situation where a taxpayer attempted to disavow S Corporation ownership for tax purposes despite claiming equity ownership in concurrent bankruptcy proceedings to secure distributions. The Second Circuit’s summary order affirms the Tax Court’s decision, offering a stark reminder regarding the consistency required in taxpayer representations across different legal venues.

The determination of whether an activity is engaged in for profit under Internal Revenue Code Section 183 constitutes a frequent area of dispute between taxpayers and the Internal Revenue Service. For tax professionals, understanding how the Tax Court weighs the nine factors provided in the Treasury Regulations is essential for advising clients with dual-purpose activities or significant losses.

In the recent case of Kolar v. Commissioner, T.C. Memo. 2026-15, the Tax Court addressed the deductibility of farm expenses incurred by a taxpayer attempting to revitalize a multi-generational family ranch. Despite a history of significant losses and substantial income from other sources—factors often fatal to a profit motive argument—the Court ruled in favor of the taxpayer. This article details the factual background, the Court’s specific application of the Section 183 factors, and the rationale leading to the decision.