This week we look at:

• Section 7508A(d) and Interest on Pre-COVID-19 Disaster Tax Deficiencies
• The Soroban Capital Partners SECA Tax Controversy
• Pleading Requirements for the Employee Retention Credit (Tapestry Senior Housing)
• ERC Causation and the Essential Business Hurdle (RAAM Construction)
• The Section 530A Transfer Tax Safe Harbor (Rev. Proc. 2026-25)
• Penalty Supervisory Approval Verification in CDP (Besicorp Group)
• Retroactive ERC Deadlines & Constitutional Challenges

This week we look at:

• Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP)

• Strict Enforcement of Tax Refund Statutes of Limitations

• Employee Retention Credit (ERC) Refund Claims & Pleading Standards

• Pandemic-Era Persistence of New York's Convenience of the Employer Rule

• Invalidity of Treasury Regulation Section 1.951A-2(c)(5)

• Non-Shareholder Capital Contributions vs. Compensation

• Final Section 1035 Exchange & Corporate Reorganization Regulations

• Reclassification of Abusive CRAT Structures as Listed Transactions

• The National Taxpayer Advocate's Perspective on AEP

This week we look at:

• Partnership Recourse Rules: Conditional DROs will not establish EROL under § 1.752-2.
• Mileage Rate Adjustment: Business standard mileage rate rises to 76 cents on July 1, 2026.
• Business Tax Account: Modernized self-service portal expands features but requires active annual maintenance.
• Litigation Legal Fees: FCRA settlements are taxable gross income without above-the-line deduction.
• Corporate Reorganizations: Tax Court invalidates regulation limiting 100% DRD in post-Loper Bright era.
• ERC Litigation Realities: Exhaustion loophole rejected; notice pleading standards approved in refund suits.
• Conservation Easements: Valuation must be grounded in immediate local market demand, not speculation.