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

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

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

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

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

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

This week we look at:

• Understanding 2026 ACA Adjustments
• Substantiating Noncash Charitable Contributions
• Filing Proper Refund Claims
• 2026 Employer Shared Responsibility Payments (ESRP)
• Changes to IRS LB&I Tax Examinations

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