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

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

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

A PDF of this week’s slides and links to supporting documents can be downloaded below:

2024-11-18 Current Federal Tax Developments

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.

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

The slides for this week’s broadcast can be downloaded from the week below.

2024-11-11 Current Federal Tax Developments

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

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

A PDF with copies of the slides and links to the authorities cited can be downloaded below:

2024-11-04 Current Federal Tax Developments

2024-10-28 IRS Releases Most 2025 Inflation Adjusted Numbers

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

You can stream or download an audio version of the broadcast below.

A PDF of the slides and documents can be downloaded as a PDF via the link below:

2024-10-28 Current Federal Tax Developments

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

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

A copy of the slides and citations can be downloaded via the link below:

2024-10-21 Current Federal Tax Developments

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

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

The slides and citations for this week’s broadcast can be downloaded as a PDF below.

2024-09-09 Current Federal Tax Developments

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

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.

2024-09-03 Current Federal Tax Developments

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

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

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

2024-08-26 Current Federal Tax Developments

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

An audio only version of this week’s session can be downloaded and streamed below:

A PDF with copies of the slides and citations can be downloaded below:

2024-08-12 Current Federal Tax Developments