2025-04-07 The Cost of Too Good to Be True

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

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Articles on this week’s developments and citations can be downloaded below:

2025-04-07 Current Federal Tax Developments

2025-03-31 End of Paper Tax Payments and Refund Checks Coming

This week we look at:

• Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021

• Interim Final Rule Limiting BOI Filing Requirements Released by Treasury Department

• Substantiating Depreciation for Converted Property: A Look at Smith v. Commissioner

• Executive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related Ones

• Jones et al. v. Commissioner: A Deep Dive into the Tax Court’s Scrutiny of a Microcaptive Insurance Arrangement

• Navigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United States

• Ninth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAs

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Articles on this week’s update can be downloaded below:

2025-03-31 Current Federal Tax Developments

2025-03-24 ERC Simplified Method for Income Tax Reporting

This week we look at:

• TIGTA Report: IRS Refund Claim Processing for Deceased Taxpayers

• IRS Certification of Seriously Delinquent Tax Debt to the State Department

• Refund Claim Challenges: When IRS Guidance Fails

• Sixth Circuit: IRA Forfeiture to Government Not Taxable

• Loper Bright: Pharmacy Benefit Managers Denied DPAD Deduction

• IRS ERC Update: Simplified Income Tax Reporting for Wage Reduction

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The articles for this week’s developments can be downloaded below:

2025-03-24 Current Federal Tax Developments

2025-03-17 IRS Guidance on When a Scam Generates a Theft Deduction

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 Regarding Whether Statute Remained Open

• IRS Memorandum Discusses When a Taxpayer Can Claim a Deduction as Victims of Various Scams Under Current Law

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Articles on this week’s developments can be downloaded from the link below:

2025-03-17 Current Federal Tax Developments

2025-03-10 Can We Mostly Ignore BOI Now?

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

An audio only version of this week’s broadcast can be downloaded or streamed below:

Articles for this week’s developments can be downloaded from the link below:

2025-03-10 Current Federal Tax Developments

2025-03-03 FinCEN Announces BOI Relief and Future Actions

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

An audio only version of this week’s broadcast can be downloaded or streamed below:

A copy of the articles for this week’s broadcast can be downloaded below:

2025-03-03 Current Federal Tax Developments

2025-02-24 BOI Developments Week

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

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The articles and citations for this week’s broadcast can be downloaded as a PDF from the link below:

2025-02-25 Current Federal Tax Developments

2025-02-17 A Week of Lost Losses

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

An audio only version of this week’s broadcast can be streamed or downloaded below;

The articles for this week’s update can be downloaded below:

2025-02-16 Current Federal Tax Developments

2025-02-10 New Administration Pushes Foward with the CTA

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

An audio only version of this week's broadcast can be downloaded or streamed from the link below.

Article for this week’s developments are available as a PDF from the link below.

2025-02-10 Currrent Federal Tax Developments

2025-02-03 A Week of Tax Court Rulings

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

An audio only version of this week’s broadcast can be streamed or downloaded below.

Articles for this week’s update can be downloaded as a PDF below:

2025-02-03 Current Federal Tax Developments

2025-01-27 BOI Sees Supreme Court Action But There a Catch

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

An audio only brodcast of this week’s update can be downloaded or streamed below:

A PDF with stories on this week’s developments can be downloaded below:

2025-01-27 Current Federal Tax Developments

2025-01-20 SECURE 2.0 Act Proposed Guidance

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

An audio only verison of this week’s broadcast can be streamed or downloaded below:

Articles on this week’s developments are contained in the PDF that can be downloaded below.

2025-01-20 Current Federal Tax Developments

2025-01-13 Tax Filing and Payment Relief for California Wildfires and More

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

An audio only version of this week’s broadcast can be downloaded or streamed below:

Articles on the developments for this week’s broadcast can be downloaeded below:

2025-01-13 Current Federal Tax Developments

2025-01-06 Digital Assets, BOI, Conservation Easements and Embezzlement

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

An audio only version of this week’s broadcast can be streamed or downloaded below.

A PDF of the slides and links to articles regarding the developments can be downloaded below.

2025-01-05 Current Federal Tax Developments

2024-12-30 BOI Developments - The Gift That Keeps on Giving

This week we look at:

• Tomato processing plant reconditioning to put plant back into shape before beginning next harvest-season production failed all events test at end of the prior season

• Tax Court again imposes functional test in case with state law limited partners

• The BOI reports have a week of dueling court rulings - from the same court

An audio only version of this week’s broadcast can be streamed or downloaded below.

A PDF with the slides and citations for this week can be downloaded below:

2024-12-30 Current Federal Tax Developments

2024-12-23 IRS Proposes Significant Revisions to Circular 230

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

An audio only version of this week’s broadcast can be streamed or downloaded below:

A PDF with the slides and citations can be downloaded viaa the link below:

2024-12-23 Current Federal Tax Developments

2024-12-16 IRS Expands Business Tax Accounts Features and Access

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

A PDF of this week’s slides and links to the cited documents can be downloaded below.

2024-12-16 Current Federal Tax Developments

2024-12-09 Nationwide Injunction on BOI Reporting

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

An audio only version of this week’s broadcast can be streamed or downloaded below:

A PDF with a copy of this week’s slides with citations can be downloaded below:

2024-12-09 Current Federal Tax Developments

2024-12-02 New Form for 83(b) Elections

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

An audio only version of this week’s broadcast can be streamed or downloaded below:

A PDF with slides and the citations for this week’s broadcast can be downloaded below.

2024-12-02 Current Federal Tax Developments

2024-11-25 IP-PINs, Divorced Parents and Children

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

An audio only version of this week’s broadcast can be streamed or downloaded below.

A PDF with this week’s slides and citations can be downloaded below.

2024-11-25 Current Federal Tax Developments