2025-06-09 Worthlessness vs Cancellation of Debt Are Not the Same

This week we look at: Court Upholds IRS’s Employee Retention Credit Guidance Taxpayer Files in US District Court as the IRS’s Failure to Act on its Appeal Was Causing the Statute of Limitations to Run Out IRS Updates K-2 and K-3 Filing Requirements FAQ, Expands Exceptions to Filing Taxpayer Advocate Releases Fiscal Year 2026 Objectives Report to Congress Trust Fund Recovery Penalties: A Case Study on "Responsible Person" and "Willfulness" Under 26 U.S.C. § 6672

This week we look at: Schwartz v. Commissioner: The Critical Role of Estimated Tax Compliance in Collection Due Process Determinations Cano v. Commissioner: Validity of Notice of Deficiency and Address Errors Key Differences Between House and Senate Tax Provisions in Reconciliation Process to Date

This week we look at: Understanding Automatic Accounting Method Changes-Revenue Procedure 2025-23 Accounting Method Changes in Conmac Investments, Inc. Conservation Easements in Glade Creek Partners, LLC Tax Treaty Exemptions in Kramarenko v. Commissioner Tax Refund Litigation & Variance Doctrine in Shleifer v. U.S. Tax Court Jurisdiction in Commissioner v. Zuch Digital Asset Reporting & Withholding in Notice 2025-33

This week we look at: Navigating Corporate Alternative Minimum Tax (CAMT) Conservation Easement Valuation & Penalties: A Warning from Tax Court Collection Due Process (CDP) & Offers in Compromise (OICs): Lessons from Tax Court Accuracy-Related Penalties: Navigating Negligence and Insufficient Professional Reliance Understanding Treasury’s Request for Information on Modernizing Federal Payments Worthlessness vs. Discharge: A Ninth Circuit Examination of Bad Debt Deductions Concurrent with COD Income

This week we look at: Self-Employment Tax for Limited Partners (Soroban II) Presidential Tariffs Under IEEPA (USCIT Decision & Federal Circuit Stay) Massachusetts Source Income (Welch Case Petition) Foreign Gift Penalties (Huang Case)  

This week we look at: IRS Reduces Estate Tax Closing Letter Fee Tax Court Scope of Review in Passport Cases Marital Deduction for Bequests to Trust “Reasonable Cause” in Late-Filing Penalty Cases “No Tax on Tips Act” (S.129) Passes Senate Transfer Pricing in Facebook, Inc. & Subsidiaries v. Commissioner Navigating New York’s Convenience Rule: Insights from Matter of Zelinsky

This week we look at: Deductibility of IVF and Gestational Surrogacy Costs Fraudulent Tax Claims & 28 U.S.C. § 2514 Tax Collection Suits & Statute of Limitations in United States v. Ragen Moving Expense Deduction - Civilian Department of Defense Contractor Eligibility Tax Court Jurisdiction - The 90-Day Deadline for Deficiency Petitions

This week we look at: Navigating the Overlap: Civil Tax Assessments and Criminal Restitution Orders Navigating Innocent Spouse Relief: A Look at Salvi v. Commissioner Supreme Court Weighs Tax Court Jurisdiction in Levy Disputes After Tax Payment: A Deep Dive into Commissioner v. Zuch Navigating ERISA Prohibited Transaction Claims: Insights from Cunningham v. Cornell University

This week we look at: Navigating the 90-Day Deadline for Employment Tax Redeterminations: The Belagio Fine Jewelry, Inc. Case and Equitable Tolling GWA, LLC v. Commissioner: Substance Over Form and the Nuances of Tax Elections for Disregarded Entities Notice 2025-23: Treasury and IRS Signal Withdrawal of Basis Shifting TOI Regulations and Related Penalties Hobby Loss and Failure to File: A Deep Dive into Himmel v. Commissioner

This week we look at: Massachusetts Source Income and the Sale of Stock by a Nonresident Navigating the Valuation Landscape: Insights from Pierce v. Commissioner Personal Liability for Corporate Sales and Use Tax: An Analysis of Matter of the Appeal of B. Wageman Navigating the IRS’s ERC Claim Processing Moratorium and "Risking" Procedures Jurisdictional Prerequisites in Tax Refund Suits: A Case Study of Estate of Robert F. Armitage, Deceased v. The United States Dependency Claims and Child Tax Credits: A Look at Correll v. Commissioner WT Art Partnership LP v. Commissioner: Charitable Contribution Deductions and Valuation Pitfalls Zajac v. Commissioner: Disallowance of Numerous Deductions and Upholding Penalties Hampton v. Commissioner: Public Policy and Disallowance of Shareholder Loss Deduction Revised SIFL Rates for Valuation of Noncommercial Flights: Revenue Ruling 2025-9 IRS Provides Limited Penalty Relief for Certain Micro-Captive Disclosure Statements The Demise of DeFi Broker Reporting: An Analysis of H.J. Res. 25