This week we look at:

• Syndicated Conservation Easements and the Valuation Conundrum: An Analysis of T.C. Memo. 2026-36
• Analysis of Garcia-Rojas v. Franchise Tax Board: The Limits of the Unitary Business Doctrine for Sole Proprietors
• An Analysis of the Reinstated Significant Issue Letter Ruling Program Under Revenue Procedure 2026-21
• The "Byers Rule" and the Administrative Procedure Act
• Jurisdictional Time Bars and the Timely Mailing Rule: An Analysis of Dunlap v. United States
• Temporary Import Surcharges and Executive Authority: A Review of the Court of International Trade's Ruling

“The words ‘outsourcing’ and ‘offshoring,' I think everyone’s burnt out by those, right? I want to make sure you’re using a good provider that has the right infrastructure in place … the right model that aligns with your vision.” Laurence Whittam | LinkedIn

 FICPA Members: Discover additional tools and resources in the FICPA Small Firm Suite.

This month, we are joined by Chris Cromer, Director of Operations with CPA.com, who provides expert insights, strategies and solutions your firm needs to deliver higher-level services and also is the operator of a top-level domain called .CPA.

"Instead of .COM we're .CPA, which is restricted to the CPA profession. You have to be a licensed CPA or CPA firm in order to register a .CPA domain."

FICPA Members: Discover additional tools and resources in the FICPA Small Firm Suite.

This month, we are joined by Frank Tumminello, CEO and Co-Founder of FileForms, who aims to help FICPA members in stopping the manual tracking of entity compliance.

FICPA Members: Discover additional tools and resources in the FICPA Small Firm Suite at Small Firm Suite - Florida Institute of CPAs.

https://www.currentfederaltaxdevelopments.com/podcasts/2026/5/3/2026-05-04-treasury-previews-upcoming-280e-medical-marijuana-guidance

This week we look at:

• Reasonable Cause Relief Under the Small-Corporation Provision for Form 5472 Penalties
• Extending the Statute of Limitations for Disallowed ERC Claims
• Legislative Update: House Passes Comprehensive Tax Administration and Relief Bills
• Anticipated IRS Guidance Following the Rescheduling of Medical Marijuana
• Analysis of the New Dyed Fuel Excise Tax Refund Regulations Under Section 6435
• Executive Order on Retirement Savings and Its Interaction with IRC Section 6433

https://www.currentfederaltaxdevelopments.com/podcasts/2026/4/25/2026-04-27-no-more-280e-for-state-legal-medical-cannabis-businesses

This week we look at:

• Tax Implications of the Rescheduling of State-Licensed Medical Marijuana
• Disallowance of COVID-19 Leave Credits: A Review of Substantiation and Trade or Business Requirements
• Substantiation, Entity Indebtedness, and Business Expense Deductibility: An Analysis of the Simmons Case
• The Tenth Circuit Codifies the Reach of the Economic Substance Doctrine Over Mechanical Statutory Compliance
• Treatment of Loyalty Rewards Program Funds and the Claim of Right Doctrine
• Valuation and Penalty Controversies in Estate Tax Examinations

https://www.currentfederaltaxdevelopments.com/podcasts/2026/4/19/2026-04-20-final-regulations-issued-on-qualified-tip-income

This week we look at:

• A Technical Analysis of the Final Section 224 Regulations on the Qualified Tip Deduction
• Analysis of Proposed Regulations on Information Reporting Thresholds and Wagering Losses (REG-113229-25)
• U.S. District Court Splits Its Ruling on Micro-Captive Disclosure Mandates
• IRS Reduces Enrolled Agent Special Enrollment Examination User Fees: An Analysis of the Interim Final and Proposed Regulations
• Taxation of Terminated Life Insurance Policies: An Analysis of Constructive Receipt and Investment Interest

• Corporate Capacity and State Law Revivor
• Digital Asset Identification Relief
• Interest and Bonus Depreciation Relief
• ERC Disallowances and Legal Standing
• Substantiation Rules for Emergency Vehicles
• Partnership Audits and Due Process
• Social Security Repayments

https://www.currentfederaltaxdevelopments.com/podcasts/2026/3/15/2026-03-16-trump-account-proposed-regulations

This week we look at:

• Proposed Regulations for IRC Section 530A "Trump Accounts"
• IRC Section 6434 Trump Account Pilot Program
• Micro-Captive Scrutiny Formalized
• BBA Audits: Notice Defects and the Statute of Limitations

https://www.currentfederaltaxdevelopments.com/podcasts/2026/3/8/2026-03-09-sir-you-are-about-to-lose-your-passport

This week we look at:

• Fiduciary and Beneficiary Liability for Unpaid Estate Taxes
• Retroactive Entity Classification and Partnership Basis
• 2026 Passenger Auto Depreciation Limits
• Passport Certification & Victimization Defenses
• Passport Revocation in Collection Suits
• Waiver of Foreign Earned Income Exclusion Time Rules
• New Digital Asset Reporting Landscape (Form 1099-DA)

https://www.currentfederaltaxdevelopments.com/podcasts/2026/3/1/2026-03-02-another-circuit-find-irs-has-assessment-authority-for-section-6038b-penalties

This week we look at:

• Required Minimum Distribution Regulations Delay
• CDP Proceedings and Underlying Liabilities
• Section 743(b) Adjustments and Economic Substance
• Assessability of Section 6038(b) Penalties

https://www.currentfederaltaxdevelopments.com/podcasts/2026/2/22/2026-02-23-supreme-court-strikes-down-tariffs 

This week we look at:

• Supreme Court Invalidates Executive Tariffs Under IEEPA
• Special Depreciation Allowance Under the OBBBA
• CAMT Adjustments and Relief
• Circuit Split on Third-Party Fraud
• Valuation and Penalties in Syndicated Conservation Easements

This week we look at:

• TEFRA Jurisdiction and the "Limited Partner" Exception
• Artificial Intelligence and Substantiation
• Section 183 Profit Motive
• Rebate vs. Nonrebate Refunds
• Substantiation and Civil Fraud
• Consolidated Return Jurisdiction

https://www.currentfederaltaxdevelopments.com/podcasts/2026/2/8/2026-02-09-another-former-spouse-ends-up-with-a-jackpot-when-her-ex-spouse-dies-due-to-erisa

This week we look at:

• The "Charitable LLC" Tax Shelter
• Section 280E Bars ERC for Cannabis Businesses
• TEFRA Intervention by Majority Partners
• R&D Credit Substantiation
• Supervisory Approval of Penalties
• ERISA Beneficiary Designations

https://www.currentfederaltaxdevelopments.com/podcasts/2026/1/31/2026-02-02-paper-refund-checks-notices-and-patience-now 

This week we look at:

• Challenging the Presumption of Delivery (CDP Cases)
• Bank Deposits & Conduit Theory
• Mandates Under Executive Order 14247 (Notice CP53E)
• IRS Implementation of Executive Order 14247 - (FS 2026-02)
• Federal Priority Statute Liability
• FASIT Structure & Substantial Compliance

https://www.currentfederaltaxdevelopments.com/podcasts/2026/1/25/2026-01-26-court-allows-erc-claim-to-go-forward-but-throws-out-apa-challenge 

This week we look at:

• ERC Refund Suits and Challenges to IRS Notice 2021-20
• Section 6015(f) Equitable Relief and Attribution of Income
• Financial Disability Tolling under § 6511(h)
• Distinguishing "Tax Loss" for Sentencing vs. Restitution
• Implementation of Qualified Overtime Deductions (OBBBA)

https://www.currentfederaltaxdevelopments.com/podcasts/2026/1/18/2026-01-19-fifth-circuit-reverses-tax-court-on-se-income-for-state-law-limited-partners

This week we look at:

• SE Tax Liability for Limited Partners (Sirius Solutions)
• Whistleblower Awards and "Collected Proceeds"
• Statutory Construction of Section 168(k) Amendments
• Updated Safe Harbor Explanations for Section 402(f)
• Modernized Group Tax Exemption Framework
• Tax-Exempt Status of Supplemental Military Housing Allowances

https://www.currentfederaltaxdevelopments.com/podcasts/2026/1/10/2026-01-12-irs-announces-opening-of-e-filing-season-for-individuals

This week we look at:

• IRS Announces Filing Season Overview & Timeline
• A Charity Loses Its §501(c)(3) Status After Forgetting to Perform Virtually Any Exempt Activities
• Taxpayer Loses a Large Charitable Contribution Deduction Based on Lack of Substantiation
• Second Circuit Concurs With Other Circuits on Willfulness for FBAR Penalties
• Tax Court Found Summary Assessment Invalid in Premium Tax Credit Case

https://www.currentfederaltaxdevelopments.com/podcasts/2026/1/3/2026-01-05-proposed-regulations-on-new-car-loan-interest-deduction

This week we look at:

• Standard Mileage Rates & Notice 2026-10
• 2026 Procedural Updates - Annual Revenue Procedures
• Qualified Passenger Vehicle Loan Interest (QPVLI) Proposed Regulations
• Estate of Spenlinhauer v. Commissioner Late Filing and More
• Bargain Sale of For-Profit colleges to a Non-Profit (501(c)(3))

https://www.currentfederaltaxdevelopments.com/podcasts/2025/12/28/2025-12-29-marijuana-rescheduling-restarts-after-long-pause

This week we look at:

• Executive Action on Marijuana Scheduling and IRC § 280E
• State Paid Family and Medical Leave (PFML) Programs
• Estimated Tax Relief for Qualified Farmland Sales
• IRC § 163(j) Interest Limitation Updates
• Premium Tax Credit (PTC) Revisions

• Section 25F Advance Elections
• Unreported Income & The "Missing Witness"
• Constitutionality of Penalties Post-Jarkesy
• Section 280E & Offers-in-Compromise
• Substantiating Bad Debt & NOLs

https://www.currentfederaltaxdevelopments.com/podcasts/2025/12/13/2025-12-15-postmark-date-risk-due-to-usps-change

This week we look at

• USPS Changes to Postmark Date System
• H.R. 1491: Disaster Related Extension of Deadlines Act
• Capitalization Priorities: Temnorod v. Commissioner
• Notice 2026-5: HSA Expansion Under OBBBA
• Fulfillment by Amazon (FBA) and "Doing Business"
• Substantiation Failures: Mirch v. Commissioner

• Notice 2025-68 – Implementation of Trump Accounts
• Draft Form 4547 – Elections and Filing Mechanics
• Notice 2025-70 – The OBBBA Scholarship Tax Credit
• Alioto v. Commissioner – Corporate Distinctness

https://www.currentfederaltaxdevelopments.com/podcasts/2025/11/29/2025-12-01-irs-gives-first-discussion-of-upcoming-credit-for-donation-to-tuition-organizations

This week we look at:

• Whistleblower Awards and Substantial Contribution
• Corporate Stock Repurchase Excise Tax
• Judicial Review of Willful FBAR Penalties
• Revisiting the Profit Motive Standard
• Judicial Precedent on Erroneous Refund Recovery
• OBBBA Guidance on SFCs and Section 987 Elections
• The OBBBA Scholarship Tax Credit
• Conservation Easements and Gross Valuation Misstatements

https://www.currentfederaltaxdevelopments.com/podcasts/2025/11/23/2025-11-24-tips-and-overtime-form-1040-reporting-reiief

This week we look at:

• Innocent Spouse Relief Determination Standards
• Adjustments to Medicare Parts A, B, and D
• Equitable Distribution vs. Alimony (Pre-TCJA)
• Implementation of the Section 139L Interest Exclusion
• OBBBA Deductions for Tips and Overtime Compensation for 2025 returns

https://www.currentfederaltaxdevelopments.com/podcasts/2025/11/15/2025-11-17-retirement-plan-and-ira-inflation-numbers

This week we look at:

• Annual Adjustments to Retirement Plan Limitations
• Ensuring Investment Trust Status for Digital Asset Staking Entities
• Examining Penalties in Microcaptive Transactions
• Ownership Requirements for Non-Business Theft Losses
• Defining the Scope of I.R.C. § 172(b)(3) Carryback Waivers

https://www.currentfederaltaxdevelopments.com/podcasts/2025/11/9/2025-11-10-employer-guidance-for-2025-qualified-tips-and-overtime

This week we look at:

• Private Inurement and Operational Failure
• Prevailing Party Status Under § 7430
• The Federal Priority Statute and Corporate Officer Liability
• Termination of the Automatic Stay in Bankruptcy
• Injunction Violations and Civil Contempt for Tax Preparer
• A Refined Approach to Math Error Notices
• Application of Unstated Interest Rules to Corporate Mergers

https://www.currentfederaltaxdevelopments.com/podcasts/2025/11/9/2025-11-10-employer-guidance-for-2025-qualified-tips-and-overtime

This week we look at:

• Conservation Easement Valuation and Highest and Best Use
• Trust Fund Recovery Penalty (TFRP) Application
• California Residency and Taxpayer Burden of Proof
• OBBBA Information Reporting Transition Relief
• SCOTUS Oral Argument on IEEPA Tariffs
• Conservation Easement Timing and Penalties
• Digital Asset Broker Reporting FAQ Guidance

https://www.currentfederaltaxdevelopments.com/podcasts/2025/10/26/2025-10-27-more-irs-government-shutdown-clarifications

This week we look at:

• Reevaluating the DC-QIE Exception (FIRPTA)
• Technical Revisions to Revenue Procedure 2025-32
• Transitional Reporting for Qualified Passenger Vehicle Loan Interest (QPVLI)
• Jurisdictional Clarity for TEFRA Readjustment Petitions
• S Corporation Income Attribution and Substantiation Failures
• IRS Operations During a Lapse in Appropriations
• Employee Retention Credit Compliance (OBBBA)
• Form 1099-K Information Reporting Updates

https://www.currentfederaltaxdevelopments.com/podcasts/2025/10/19/2025-10-20-who-owns-a-hotels-ertc-refund

This week we look at:

• Employee Retention Credit Refunds in Bankruptcy
• Lawsuit Settlement Enforcement and Tax Disclosure Obligations
• Operational Test Failure: Commercial Activities and Private Benefit
• IRS E-File Suspension Authority
• Taxation of International Investment Losses
• Collection Due Process Analysis

https://www.currentfederaltaxdevelopments.com/podcasts/2025/10/10/2025-10-13-2026-tax-year-inflation-numbers-published

This week we look at:

• Updated SIFL Rates for Noncommercial Employer-Provided Flights
• Supervisory Approval, Reasoned Decision Making, and the Limits of APA Review in Tax Court
• Tax Exemption Denial for a Gated Community HOA by the Tax Court
• Cancellation-of-Indebtedness Income Timing and the Variance Doctrine
• IRS Contingency Planning: Operational Impact on Tax Practice and Filing Season Preparedness
• 2026 Inflation Adjustments for Tax Professionals
• Accounting Method Failures and Income Reconstruction
• The Concrete Injury Requirement in ERTC Consultant Litigation

https://www.currentfederaltaxdevelopments.com/blog/2025/10/4/2025-10-06-guidance-push-in-shutdown-week

This week we look at

• IRS Updates PTIN User Fee
• Withdrawal of Corporate Reorganization Proposed Regulations
• IRS FY2026 Shutdown Contingency Plan
• Guidance on Rural Qualified Opportunity Zones
• New Interim Guidance on the Corporate AMT
• Tax Relief Extension for Terroristic Action in Israel
• Final Regulations on Interest Capitalization for Improvements
• Eighth Circuit Reverses Tax Court in 3M on Blocked Income
• District Court Finds § 501(c)(4) Standards Unconstitutionally Vague
• Two Tax Court Opinions in Green (Hobby Lobby)

https://www.currentfederaltaxdevelopments.com/podcasts/2025/9/27/2025-09-29-the-end-of-individual-refund-checks-approaches

This week we look at:

• Hobby Loss Rules: Young v. Commissioner, T.C. Memo. 2025-95
• Drought-Forced Livestock Sales: IRS Notice 2025-52
• Per Diem Rates: IRS Notice 2025-54
• End of Paper Refunds: IR-2025-94 / E.O. 14247
• Syndicated Conservation Easements: Jackson Stone South, LLC v. Commissioner, T.C. Memo. 2025-96
• Constructive Receipt & § 4958: Fumo v. Commissioner, T.C. Memo. 2025-97
• Whistleblower Awards: In re: Sealed Case, CA DC, Case No. 24-1001
• Employee vs. Independent Contractor: Gil v. United States, USDC ED PA

https://www.currentfederaltaxdevelopments.com/podcasts/2025/9/20/2025-09-22-catch-up-contribution-secure-20-regulations-released

This week we look at:

• Final Regulations for Catch-Up Contributions (TD 10033)
• Draft Schedule 1-A (Form 1040) for 2025
• Urgent Warnings of State Revenue Department Phishing Scams
• Tax Court Developments (Blomquist Holdings)
• Proposed Tax Administration Legislation
• New Deduction for Qualified Tips: An Overview of Proposed Treasury Regulation §1.224-1

https://www.currentfederaltaxdevelopments.com/podcasts/2025/9/13/2025-09-15-qbi-deduction-w-2-wages-and-section-280e

This week we look at:

• Court Frowns on Professional’s Use of Randomly Generated Social Security Numbers
• Understanding the “Placed in Service” Rule for Electric Vehicle Credits
• Advisers Found to Owe Treble Damages to Impacted Taxpayers
• W-2 Wages and the Qualified Business Income Deduction Under Section 280E
• Trust Fund Recovery Penalties and Refund Claim Timeliness in Richter v. The United States

https://www.currentfederaltaxdevelopments.com/podcasts/2025/9/6/2025-09-08-irs-releases-preliminary-list-of-eligible-qualified-tip-occupations 

This week we look at:

• Eleventh Circuit: Gross Valuation Misstatement Penalty in a Conservation Easement Case
• Treasury & IRS: Preliminary Guidance on Tipped Occupations
• Eighth Circuit: Medtronic Transfer Pricing Dispute Remanded Again
• California OTA: Entertainer Found to be a California Resident
• Pitfalls in IRA Bankruptcy Exemptions: Farber v. Feldman

https://www.currentfederaltaxdevelopments.com/podcasts/2025/9/1/2025-09-02-better-late-than-never-rampe-procedural-relief

This week we look at:

• Federal Circuit Ruling Finds Limits on Executive Authority to Impose Tariffs Under IEEPA
• Introduction to OBBBA R&E Expenditure Procedures
• Sixth Circuit Realigns on Tax Court Jurisdiction
• Innocent Spouse Relief: Walsh v. Commissioner Overview
• Taxpayer Precluded from Challenging Liability: Sullivan v. Commissioner
• 60-Day IRA Rollover Waiver in a Fraud Scenario

https://www.currentfederaltaxdevelopments.com/podcasts/2025/8/24/2025-08-25-stump-the-llm

This week we look at:

• Federal Complaint Seeking ERC Refunds: Superior Pediatric Care v. United States
• Proposed Revisions to Partnership Information Reporting for Sales or Exchanges of Interests—Form 8308
• Taxation of Unsolicited Stock Transfers: Analysis of Feige v. Commissioner
• Third-Party Intent and the Indefinite Assessment Period: An Analysis of Murrin v. Commissioner
• The One, Big, Beautiful Bill Act (OBBBA): New Deductions & Energy Credit Modifications
• LLM Limitations in Tax Law: Beyond Memorization

https://www.currentfederaltaxdevelopments.com/podcasts/2025/8/17/2025-08-18-state-tax-credit-salt-workaround-regulation-challenge-fails

This week we look at:

• Denham Outlines Its Criticisms of the Tax Court’s Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals
• Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner
• Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility
• The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners
• Understanding New Clean Electricity Credit Termination Rules Impact of IRS Notice 2025-42 on Wind and Solar Facilities

https://www.currentfederaltaxdevelopments.com/podcasts/2025/8/10/2025-08-11-irs-announces-no-payroll-changes-for-2025

This week we look at:

• Urgent Guidance Requested on Section 174A Domestic Research and Experimental Expenditures
• Post-Referral Authority in Tax Litigation—IRS Lacked Authority to Approve ERC Refund
• Closer This Time, But Still Not Quite There—Another Microcaptive Loss for the Taxpayers
• Proposed Amendments to IRC Section 132 Fringe Benefit Rules: Switching to NAICS
• Understanding Passthrough Losses and Bankruptcy in Field Attorney Advice 20253101F
• Proactive Engagement with the Office of Professional Responsibility
• IRS Announces Policy for the One Big Beautiful Bill Act for 2025 Payroll Issues

https://www.currentfederaltaxdevelopments.com/podcasts/2025/8/2/2025-08-04-a-late-tax-season-start-expected

This week we look at:

• Filing Season Forecast to Start in Mid-February in the Coming Season
• Settlement Proceeds Found to Be Taxable and Taxpayer Stuck With Late-Filing Penalties
• IRS Issues Relief for Certain Issues Related to Partnership Investments and the Corporate Alternative Minimum Tax
• Corporate Mergers and the Same Taxpayer Rule for Interest Netting
• What Is an Educational Organization for Unrelated Business Income Tax (UBIT) Purposes?
• Another Microcaptive Arrangement Falls Under Court Challenge
• Taxpayer’s Claim She Didn’t Consent to the Filing of a Joint Return Didn’t Impact Denial of Innocent Spouse Relief

https://www.currentfederaltaxdevelopments.com/podcasts/2025/7/19/2025-07-21-dealing-with-uncashed-retirement-plan-checks

This week we look at:

• Conservation Easement Deductions: A Critical Review of Rock Cliff Reserve, LLC
• Portability Election Pitfalls: A Deep Dive into Estate of Rowland and DSUE Requirements
• Understanding Equitable Tolling in Tax Court: Insights from Boechler, P.C. v. Commissioner
• A Critical Review of Veribest Vesta, LLC v. Commissioner of Internal Revenue: Implications for Conservation Easement Valuations
• Understanding Withholding and Reporting for Uncashed Retirement Plan Distribution Checks: A Review of Rev. Rul. 2025-15
• Fifth Circuit Affirms Tax Court’s Disallowance of Micro-Captive Insurance Deductions: An Analysis of Swift v. Commissioner

https://www.currentfederaltaxdevelopments.com/podcasts/2025/7/14/2025-07-14-passage-of-a-much-shorter-additional-tax-bill

This week we look at:

• Recent Developments: Interpreting the Johnson Amendment in Tax-Exempt Status Litigation
• An Examination of Contract Formation in Tax Court Settlement: Insights from Arden Row Assets, LLC
• Jurisdictional Imperatives in Tax Court: A Case Study on Timeliness and Last Known Address
• Expanding Horizons: Potential Changes to Disaster Tax Relief Under the Filing Relief for Natural Disasters Act

https://www.currentfederaltaxdevelopments.com/podcasts/2025/7/7/2025-07-07-win-some-lose-some-on-statutes-of-limitations-for-the-irs

This week we look at:

• Bad Debt Deduction and Accuracy-Related Penalties: Key Takeaways from Anaheim Arena Management, LLC v Commissioner
• FBAR Compliance and the CPA’s Due Diligence Under Circular 230
• Dissecting Partnership Audit Limitations: Insights from JM Assets, LP v. Commissioner
• Decoding Penalty Assessments: A Deep Dive into Moxon Corporation v. Commissioner
• Tax Court Scrutiny: Upholding Civil Fraud Penalties in Beleiu v. Commissioner

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/30/2025-06-30-erc-issues-return-to-court

This week we look at:

• Court Upholds IRS’s Employee Retention Credit Guidance
• Taxpayer Files in US District Court as the IRS’s Failure to Act on its Appeal Was Causing the Statute of Limitations to Run Out
• IRS Updates K-2 and K-3 Filing Requirements FAQ, Expands Exceptions to Filing
• Taxpayer Advocate Releases Fiscal Year 2026 Objectives Report to Congress
• Trust Fund Recovery Penalties: A Case Study on "Responsible Person" and "Willfulness" Under 26 U.S.C. § 6672

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/22/2025-06-23-senate-finance-committee-tax-provision-draft-issued

This week we look at:

• Schwartz v. Commissioner: The Critical Role of Estimated Tax Compliance in Collection Due Process Determinations
• Cano v. Commissioner: Validity of Notice of Deficiency and Address Errors
• Key Differences Between House and Senate Tax Provisions in Reconciliation Process to Date

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/16/2025-06-16-the-case-of-the-vanishing-levy

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 & Withholding in Notice 2025-33

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/8/2025-06-09-worthlessness-vs-cancellation-of-debt-are-not-the-same

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
• Worthlessness vs. Discharge: A Ninth Circuit Examination of Bad Debt Deductions Concurrent with COD Income
• Navigating the Religious Exemption Landscape: A Deep Dive into Unemployment Compensation Tax

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/2/2025-06-02-revisiting-previously-discussed-cases

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)

https://www.currentfederaltaxdevelopments.com/podcasts/2025/5/26/2025-05-26-second-challenge-to-convenience-of-the-employer-rule

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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/5/18/2025-05-19-passthroughs-and-the-one-big-beautiful-bill

This week we look at:

• IRC Section 7433 and the Scope of the Collection Waiver of Sovereign Immunity
• The Claim of Right Doctrine Applied to Business Errors
• IRC Section 7433: Reinforcing Collection vs. Assessment Distinction
• Selected issues from The One, Big, Beautiful Bill’s tax provisions
• Proposed Changes to the Section 199A Qualified Business Income Deduction
• Proposed Changes Affecting Passthrough Entities and State PTE Taxes
• Interest Deductions and Penalties in Complex Financial Transactions

https://www.currentfederaltaxdevelopments.com/podcasts/2025/5/9/2025-05-12-taxpayer-fails-to-qualify-for-deduction-for-dod-ordered-move

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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/5/2/2025-05-05-will-we-see-pl-86-272-finally-revised

This week we look at:

• ERC Claims Filed Without Schedule R
• Reasonable Cause for Information Return Penalties: Reliance on Software
• Proposed Expansion of P.L. 86-272 "Solicitation of Orders" Definition
• 2026 Inflation Adjustments for HSAs and Excepted Benefit HRAs

https://www.currentfederaltaxdevelopments.com/podcasts/2025/4/25/2025-04-28-twice-to-the-supreme-court

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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/4/18/2025-04-21-hobby-horse-problems

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 Dive into Himmel v. Commissioner

https://www.currentfederaltaxdevelopments.com/podcasts/2025/4/16/2025-04-16-a-very-busy-week-as-the-deadline-approached

This week we look at:

• Massachusetts Source Income and the Sale of Stock by 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 Study of Estate of Robert F. Armitage, Deceased v. The United States
• Dependency Claims and Child Tax Credits: A Look at Correll v. Commissioner
• WT Art Partnership LP v. Commissioner: Charitable Contribution Deductions and Valuation Pitfalls
• Zajac v. Commissioner: Disallowance of Numerous Deductions and Upholding Penalties
• Hampton v. Commissioner: Public Policy and Disallowance of Shareholder Loss Deduction
• Revised SIFL Rates for Valuation of Noncommercial Flights: Revenue Ruling 2025-9
• IRS Provides Limited Penalty Relief for Certain Micro-Captive Disclosure Statements
• The Demise of DeFi Broker Reporting: An Analysis of H.J. Res. 25

https://www.currentfederaltaxdevelopments.com/podcasts/2025/4/6/2025-04-07-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/3/30/2025-03-31-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/3/24/2025-03-24-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/3/16/2025-03-17-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/3/9/2025-03-10-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/3/2/2025-03-03-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/2/23/2025-02-24-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/2/16/2025-02-17-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/2/8/2025-02-10-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/2/2/2025-02-03-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/1/26/2025-01-27-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/1/19/2025-01-20-secure-20-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/1/12/2025-01-13-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

https://www.currentfederaltaxdevelopments.com/podcasts/2025/1/5/2025-01-06-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

https://www.currentfederaltaxdevelopments.com/podcasts/2024/12/28/2024-12-30-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

https://www.currentfederaltaxdevelopments.com/podcasts/2024/12/22/2024-12-23-irs-proposes-signficant-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

https://www.currentfederaltaxdevelopments.com/podcasts/2024/12/14/2024-12-16-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

https://www.currentfederaltaxdevelopments.com/podcasts/2024/12/8/2024-12-09-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

https://www.currentfederaltaxdevelopments.com/podcasts/2024/11/30/2024-12-02-new-form-for-83b-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

https://www.currentfederaltaxdevelopments.com/podcasts/2024/11/24/2024-11-25-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.

https://www.currentfederaltaxdevelopments.com/podcasts/2024/11/16/2024-11-18-end-of-partnership-suspense-account-at-the-irs

This week we look at:

• IRS may stop putting “taxpayer may rely” statements on proposed regulations
• Tax Court rules partnership basis calculations are cumulative in nature and not stand-alone annual calculations under IRC §705
• Latest speculations on what will get through Congress in 2025 - if anything

https://www.currentfederaltaxdevelopments.com/podcasts/2024/11/9/2024-11-11-post-election-issue-on-tax-bills-and-the-reconciliation-process

This week we look at the rules involving the reconciliation process in Congress, the path that it appears most likely any tax bill enacted to deal with the expiration of many TCJA provisions at the end of 2025.

https://www.currentfederaltaxdevelopments.com/podcasts/2024/11/4/2024-11-04-retirement-plan-inflation-numbers

This week we look at:

• Retirement plan limits announced by the IRS, basically completing the tax inflation adjustments for 2025
• IRS emailed Chief Counsel Advice outlines dealing with SECA and the net investment income tax issues arising from a BBA partnership exam

https://www.currentfederaltaxdevelopments.com/podcasts/2024/10/26/2024-10-28-current-federal-tax-developments

This week we look at:

• IRS releases inflation adjusted numbers for most items aside from retirement plans for 2023
• IRS has more bad news for those who fail to pay over trust fund taxes to pay other expenses
• Another US District Court denies a preliminary injunction to bar enforcement of the BOI reporting rules

https://www.currentfederaltaxdevelopments.com/podcasts/2024/10/20/2024-10-21-staking-returns-for-one-more-try-at-court

This week we look at:

• S corporation finds multiple ways to terminate its S status, asks IRS forgiveness which is granted
• IRS rules condoms are medical expenses for tax purposes
• IRS adds items to list of preventive care an HDHP can pay without the insured having met the annual deductible
• PTIN registration opens for 2025
• Staking income challenge returns to court

https://www.currentfederaltaxdevelopments.com/podcasts/2024/9/9/2024-09-09-more-boi-report-issues

This week we look at:

• Additional BOI clarifications from online discussions regarding a CPA firm’s reporting obligations and confusions about reporting by entities that don’t register with a state for formation but which do file tax returns

https://www.currentfederaltaxdevelopments.com/podcasts/2024/9/2/2024-09-03-boi-review-time

This week we look at:

• DOJ has scheduled a December 2 hearing on the proposed rule to reschedule marijuana
• BOI reporting confusions that keep coming up as questions in online discussions - time to review

https://www.currentfederaltaxdevelopments.com/podcasts/2024/8/24/2024-08-26-irs-erc-notices-of-denial-comments-of-the-taxpayer-advocate

This week we look at:

• IRS announces the reopening of the ERC Voluntary Disclosure Program on somewhat less generous terms then the first program provided
• National Taxpayer Adviser discusses issues related to ERC Notices of Disallowance issued by the IRS

https://www.currentfederaltaxdevelopments.com/podcasts/2024/8/11/2024-08-12-internet-frauds-and-section-165

This week we look at

• Online scams and tax deductions - why how that online scammer you found on a dating site manages to take your money can make a big tax difference
• IRS announces next steps in ERC program, will begin sending some checks in September

https://www.currentfederaltaxdevelopments.com/podcasts/2024/8/4/2024-08-05-house-passed-tax-bill-fails-to-clear-cloture-vote-in-the-senate

This week we look at:

• Tax bill fails to clear a procedural vote in the Senate, reducing the likelihood we’ll see the bill enacted before this Congress leaves office
• US District Court declines to issue preliminary injunction requiring the IRS to terminate the ERC claim moratorium, but finds much the court liked in the plaintiff’s arguments

https://www.currentfederaltaxdevelopments.com/podcasts/2024/7/28/2024-07-29-more-irs-erc-guidance

This week we look at:

• FinCEN adds two more questions to BOI FAQ page
• IRS adds five new warning signs for problematic ERC claims and announces new developments coming in ERC enforcement
• Chief Counsel Memorandum outlines position on tax exempt organizations dealing with §52 provisions for ERC

https://www.currentfederaltaxdevelopments.com/podcasts/2024/7/21/2024-07-22-ira-finalizes-rmd-regulations

This week we look at:

• Taxpayer can’t simply rely on tax software when preparing their return, even if they aren’t being nominated for Secretary of Treasury
• IRS finalizes SECURE Act/SECURE 2.0 Act required minimum distributions regulations
• IRS proposed regulations address the problem of determining the applicable age for those born in 1959

https://www.currentfederaltaxdevelopments.com/podcasts

This week we look at:

• FinCEN updates the FAQs for BOI reporting, adding information about entities that cease to exist

• New Jersey Committee on Unauthorized Practice of Law releases letter outlining when CPAs and EAs may prepare and/or file BOI reports for clients without the assistance of an attorney

• Another PLR issued for missed ESBT elections for trusts that qualified to make such elections

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

https://www.currentfederaltaxdevelopments.com/podcasts/2024/7/7/2024-07-08-supreme-court-makes-it-easier-to-challenge-regulations

This week we look at

• End of term US Supreme Court cases that will likely impact challenges to Treasury regulations, overturning the concept of Chevron deference and extending the statute to challenge regulations under the Administrative Procedures Act

https://www.currentfederaltaxdevelopments.com/podcasts/2024/6/30/2024-07-01-irs-to-eventually-automate-fta-relief

This week we look at:

• Ninth Circuit rules that statute of limitations for the IRS to sue for recovery of erroneous refund begins when the check clears the Federal Reserve and is approved for payment by the US Treasury
• IRS National Taxpayer Advocate announces the IRS will automate FTA abatement of penalties beginning in 2026
• Attorneys report some ERC claimants now interesting in filing suit to accelerate their claim processing

https://www.currentfederaltaxdevelopments.com/podcasts/2024/6/23/2024-06-24-supreme-court-upholds-the-965-transition-tax

This week we look at:

• The Supreme Court rules, in a more divided than it may appear opinion, that the §965 transition tax is Constitutional, sustaining the result from the Ninth Circuit in the Moore case.
• IRS gives interim guidance for special distribution relief in the SECURE Act 2.0 for certain distributions.
• IRS indicates it will now be (slowly) processing ERC claims, vast majority show issues

https://www.currentfederaltaxdevelopments.com/podcasts/2024/6/16/2024-06-17-do-not-believe-your-chatbot-on-tax-matters

This week we look at:

• IRS provides last minute relief for payment of second quarter corporate estimated tax payments related to corporate alternative minimum tax
• En-banc rehearing request denied in case of Farhy v. Commissioner by DC Circuit
• CPA pleads guilty to tax charges related to syndicated conservation easement program
• Taxpayer Advocate warns of relying on generative AI for answering tax questions for consumer tax software - and there are just as big of issues for tax professionals

https://www.currentfederaltaxdevelopments.com/podcasts/2024/6/9/2024-06-10-estate-tax-problems-for-buy-sells-funded-by-life-insurance

This week we look at:

• US Supreme Court rules that a requirement to redeem the decedent’s shares cannot be considered to reduce the value of the entity, but life insurance proceeds received by the entity to fund the buyout will increase the value
• Taxpayer denied relief for late rollover when funds were accidentally transferred from employer plan to Roth IRA
• IRS rules certain payments related to East Palestine, Ohio derailment are §139 disaster payments
• What options exist for an employer with a pending ERC claim?

https://www.currentfederaltaxdevelopments.com/podcasts/2024/6/2/2024-06-03-llc-as-an-s-corporation-issue

This week we look at:

• IRS announces that Direct File will continue into 2025 and be expanded while maintaining other program
• A taxpayer finds its not so simple as just file a Form 2553 if you want to have an LLC taxed as an S corporation, but did realize the error fast enough to get a PLR to restore S status

https://www.currentfederaltaxdevelopments.com/podcasts/2024/5/27/2024-05-27-misleading-silences-are-sometimes-fine-in-tax

This week we look at:

• Yet another PLR requested for missed QSST election after S shares moved to trust following death of a shareholder
• Tax preparer’s conviction for willfully filing false returns upheld on appeal despite his argument he had doing what he did for years
• Letters to taxpayer from IRS Appeals did not extend the time to file suit for a claim for refund
• A partnership had properly elected to use BBA audit provisions early, rendering IRS FPAA invalid

https://www.currentfederaltaxdevelopments.com/podcasts/2024/5/17/2024-05-20-erc-battles-continue

This week we look at:

• DOJ issues proposed rule that would remove cannabis businesses from loss of most business deductions under IRC §280E
• Filing date relief issued for those impacted by Ohio tornadoes from March
• IRS National Fraud Counsel speaks on ERC exams in ABA Tax Section webinar
• Tax adviser files suit to attempt to force the IRS to start processing ERC claims
• Tax Court imposes penalty for raising frivolous claims against taxpayer who argued wages are not income (among other things)

https://www.currentfederaltaxdevelopments.com/podcasts/2024/5/12/2024-05-13-changes-to-cafs-and-process-for-tax-pros-to-obtain-transcripts

This week we look at:

• IRS gives update on final results for ERC voluntary compliance program and discusses the future
• The taxpayer’s contract did not make payment contingent on the success of research
• DOJ announces CPA firm barred from promoting CRAT/single premium annuity shelter
• IRS provides information on CAF “under review status” and changes to requesting transcripts

https://www.currentfederaltaxdevelopments.com/podcasts 

This week we look at:

• IRS releases Fact Sheet on disaster provisions for retirement accounts added by SECURE 2.0 Act
• DC Circuit reverses Tax Court ruling that IRS does not have assessment authority for failure to file a report under IRC §6038(b) (Form 5471)
• Electric vehicle final regulations issued
• Department of Justice begins process to move marijuana from Schedule I to Schedule III which would cause §280E to no longer limit deductions for cannabis businesses
• Lack of any written records on time President/COO spent on activities or even estimate time spent on qualified research activities doomed attempt to claim a credit under IRC §41(a)

https://www.currentfederaltaxdevelopments.com/podcasts/2024/4/28/2024-04-29-no-minimum-attention-required-for-supervisor-approval-of-penalties-per-tax-court

This week we look at:

• Final regulations issued on credit transfer provisions of the Inflation Reduction Act
• Tax Court rules the law does mandate a minimum level of attention by a supervisor when approving a proposed penalty
• IRS announces the end of the Direct File pilot and will announce the next steps shortly