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

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

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

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

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

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)

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

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