Clients increasingly show up with tax positions backed by blog posts, podcasts, social media, and AI, but how much of that actually counts? Jeremy walks through the closed list of sources the regulations recognize as authority, from the Code and Treasury regulations to court cases and revenue rulings, and explains why IRS publications, form instructions, and even other tax professionals’ opinions don’t make the cut. He also covers how to weigh supporting and contrary authorities against each other, and why that matters for the Section 6662 substantial understatement penalty.

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Jeremy unpacks the "no tax on overtime" deduction created by the One Big Beautiful Bill Act, explaining why the name is misleading since qualified overtime compensation is still taxable income subject to withholding, FICA, and (in most states) state tax. He walks through how to isolate the FLSA overtime premium from gross overtime pay, calculate the deduction on the new Schedule 1A, and apply the filing status caps and MAGI phaseouts through real client examples. He also flags the reporting changes coming in 2026, when employers must correctly report the amounts on Form W-2, Box 12, Code TT, and the relaxed 2025 transition rules disappear.

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In part two of his series on protecting taxpayer information, Jeremy shifts from who can see client data to how firms actually have to secure it. He walks through the Gramm-Leach-Bliley Act, the FTC Safeguards Rule, and what a written information security plan needs to cover, then explains how SOC 2 reports help firms vet software vendors. He closes with the IRS Office of Professional Responsibility's new AI guidance under Circular 230, and what it means to treat AI like a junior staff member rather than an unsupervised practitioner.

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Jeremy opens a two-part series on taxpayer confidentiality by breaking down IRC Sections 7216 and 6713, the rules that govern how tax professionals can use and disclose tax return information. Using a case study of a solo firm owner weighing seasonal hires, an outsourced bookkeeper, and a possible merger, he walks through what actually counts as tax return information, when taxpayer consent is required, and the exceptions that let firms share data without it. He also covers what a tax return preparer and auxiliary service actually mean under the regulations, since those definitions decide whether consent is even needed in the first place.

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Jeremy closes out his partnership series by tackling outside basis, how partnership liabilities affect that basis, and what happens when a partner exits. Using a case study of two LLC members with mounting losses, he walks through abandonment, a buyout by the remaining partner, a partnership redemption, and a sale to a third party, comparing the tax results of each. He also covers Section 751 hot assets and why unrealized receivables and appreciated inventory can turn part of a capital gain into ordinary income.

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Jeremy breaks down how partnerships can divide profits among partners who contribute very different things — cash, property, or just time and effort — without running afoul of federal tax law. Using a hypothetical partnership as a running example, he covers what makes an allocation legitimate versus a tax dodge, and why the IRS cares so much about the difference.

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Jeremy digs into what actually makes someone a partner for federal tax purposes, tracing the definition back to the Supreme Court's Tower and Culbertson decisions and the "hypothetical liquidation" test for capital interests. From there, he unpacks the messier question of self-employment tax on partnership income: the undefined "limited partner as such" exception under IRC Section 1402(a)(13), and the current circuit split between the Tax Court's functional analysis (Renkemeyer, Soroban) and the Fifth Circuit's state-law approach in Sirius Solutions, with Denham Capital Management still pending at the First Circuit.

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