This week we look at:

• Congress passes H.R. 9496, creating new IRC §7511 relief for hostages and wrongful detainees.
• Rev. Proc. 2026-20 gives investment trusts holding digital assets a safe harbor for staking.
• California OTA rejects FTB's hot asset theory for nonresident partnership interest sales.
• Rev. Rul. 2026-18 publishes the SIFL rates for second-half 2026 employer aircraft flights.
• Tax Court sustains bank-deposits income, denies Cohan estimates, and abates penalty in Rahman.
• Proposed regs implement OBBBA changes to the Section 36B premium tax credit and APTC rules.
• T.D. 10059 finalizes the back-end basis adjustment rule for intragroup Section 357(c) liabilities.
• IRS postpones deadlines to February 2027 for Hurricane Isaias victims in Alabama and Florida.
• Court of Federal Claims denies ERC for a staffing agency in Southern Arizona Health Services.
• T.D. 10060 lets the IRS contract for card payment fees, recouped through a reimbursement fee.

This week we look at:

Informal claim and COVID-19 disaster relief save an untimely-looking IRA refund suit in Singh.
IRS recasts "Section 351 conversion" ETF transactions as taxable exchanges in Rev. Rul. 2026-20.
Proposed regs implement a four-year installment election for farmland sales to young farmers.
A corporate Offer-in-Compromise caps an officer's Trust Fund Recovery Penalty liability in Amodio.
Treasury completes automatic enrollment in Trump Accounts under new Section 530A regulations.
Sevillo Fine Foods: three independent grounds doom an ERC claim based on port congestion delays.
Tax Court holds Form 872-T cannot terminate a fixed-date Form 872 extension in Fine v. Commissioner.
New IRS notice extends tax deadlines to September 2027 for Israel conflict-affected taxpayers.
Congress sends the National Taxpayer Advocate independent legal counsel in H.R. 997.
New regulations build the infrastructure for the $1,700 Section 25F scholarship tax credit.

This week we look at:

• Tax Court Applies Equitable Tolling to BBA Partnership Petition Deadlines -- Kings Road Property
• District Court Voids VIBIR's Net Investment Income Tax Assessment -- Perkins
• IRS Notice 2026-55 Seeks Comments on Opportunity Zone Rules for Housing Developers
• Hurricane Michael Casualty and Charitable Deductions Fail for Lack of Substantiation -- Williams
• Treasury Raises the Estate Tax Closing Letter User Fee to $76 -- TD 10055
• Tax Court Finds Proper Mailing Despite a Defective Form 3877 -- Lindsey
• Unsubstantiated Insider Loan Triggers 225-Percent Excise Tax Exposure -- Jagannath