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.

This week we look at:

• Nominal S Corporation Ownership and the Abuse Exception
• Recapping the ERC via Section 7405
• Civil Actions Constructive Dividends, Formalities, and Civil Fraud
• CDP Hearings, Offer-In-Compromise, and RCP Calculations
• Professional Responsibility and Responsible AI Use
• Rigorous Proof for ERC "Partial Suspension" Claims

This week we look at:

• Relief from Ineffective S Corporation and QSub Elections
• Procedural and Jurisdictional Limits in Challenging IRS Guidance
• Medicaid Gross Receipts, Cohan Estimations, and Professional Reliance
• Standards and Deceit in Supervised Release
• Transitional Guidance on Qualified Opportunity Zones

This week we look at:

• Application of New Section 68 to Trusts and Estates
• Assessing the Risks of Hindsight in Late § 475(f)(1) Elections
• The Eradication of the 5% Safe Harbor (Clean Energy)
• Limits of § 2036(a) and Tax-Motivated Transfers
• Section 183 Hobby Losses & Penalties
• New Section 25F Education Freedom Tax Credit

This week we look at:

• Proposed Increase to Estate Tax Closing Letter User Fee
• Divergent Causation Standards for ERC Eligibility
• Valuation Extremes in Conservation Easements
• Substantiating Mortgage Interest Deductions
• Taxation of Cryptocurrency Staking Rewards
• Section 4960 and "Covered Employees"
• FBAR Compliance and IRS Agent Authority

This week we look at:

• Procedural Timeliness & Automatic Extensions

• Spousal IRA Rollovers Through Estates and Trusts

• Collateral Estoppel and the "Innocent" Spouse

• Improper Corporate Deductions and Fraud

• Implementation of "Trump Accounts"

• 2027 Inflation Adjustments (HSA, HRA, DPCSA)