2025-10-06 Guidance Push in Shutdown Week

This week we look at: Updated SIFL Rates for Noncommercial Employer-Provided Flights Supervisory Approval, Reasoned Decision Making, and the Limits of APA Review in Tax Court Tax Exemption Denial for a Gated Community HOA by the Tax Court Cancellation-of-Indebtedness Income Timing and the Variance Doctrine IRS Contingency Planning: Operational Impact on Tax Practice and Filing Season Preparedness 2026 Inflation Adjustments for Tax Professionals Accounting Method Failures and Income Reconstruction The Concrete Injury Requirement in ERTC Consultant Litigation

This week we look at IRS Updates PTIN User Fee Withdrawal of Corporate Reorganization Proposed Regulations IRS FY2026 Shutdown Contingency Plan Guidance on Rural Qualified Opportunity Zones New Interim Guidance on the Corporate AMT Tax Relief Extension for Terroristic Action in Israel Final Regulations on Interest Capitalization for Improvements Eighth Circuit Reverses Tax Court in 3M on Blocked Income District Court Finds § 501(c)(4) Standards Unconstitutionally Vague Two Tax Court Opinions in Green (Hobby Lobby)

This week we look at: Hobby Loss Rules: Young v. Commissioner, T.C. Memo. 2025-95 Drought-Forced Livestock Sales: IRS Notice 2025-52 Per Diem Rates: IRS Notice 2025-54 End of Paper Refunds: IR-2025-94 / E.O. 14247 Syndicated Conservation Easements: Jackson Stone South, LLC v. Commissioner, T.C. Memo. 2025-96 Constructive Receipt & § 4958: Fumo v. Commissioner, T.C. Memo. 2025-97 Whistleblower Awards: In re: Sealed Case, CA DC, Case No. 24-1001 Employee vs. Independent Contractor: Gil v. United States, USDC ED PA

This week we look at: Final Regulations for Catch-Up Contributions (TD 10033) Draft Schedule 1-A (Form 1040) for 2025 Urgent Warnings of State Revenue Department Phishing Scams Tax Court Developments (Blomquist Holdings) Proposed Tax Administration Legislation New Deduction for Qualified Tips: An Overview of Proposed Treasury Regulation §1.224-1  

This week we look at: Court Frowns on Professional’s Use of Randomly Generated Social Security Numbers  Understanding the “Placed in Service” Rule for Electric Vehicle Credits Advisers Found to Owe Treble Damages to Impacted Taxpayers W-2 Wages and the Qualified Business Income Deduction Under Section 280E Trust Fund Recovery Penalties and Refund Claim Timeliness in Richter v. The United States

This week we look at: Eleventh Circuit: Gross Valuation Misstatement Penalty in a Conservation Easement Case Treasury & IRS: Preliminary Guidance on Tipped Occupations Eighth Circuit: Medtronic Transfer Pricing Dispute Remanded Again California OTA: Entertainer Found to be a California Resident Pitfalls in IRA Bankruptcy Exemptions: Farber v. Feldman

This week we look at: Federal Circuit Ruling Finds Limits on Executive Authority to Impose Tariffs Under IEEPA Introduction to OBBBA R&E Expenditure Procedures Sixth Circuit Realigns on Tax Court Jurisdiction Innocent Spouse Relief: Walsh v. Commissioner Overview Taxpayer Precluded from Challenging Liability: Sullivan v. Commissioner 60-Day IRA Rollover Waiver in a Fraud Scenario

This week we look at: Federal Complaint Seeking ERC Refunds: Superior Pediatric Care v. United States Proposed Revisions to Partnership Information Reporting for Sales or Exchanges of Interests—Form 8308 Taxation of Unsolicited Stock Transfers: Analysis of Feige v. Commissioner Third-Party Intent and the Indefinite Assessment Period: An Analysis of Murrin v. Commissioner The One, Big, Beautiful Bill Act (OBBBA): New Deductions & Energy Credit Modifications LLM Limitations in Tax Law: Beyond Memorization

This week we look at: Denham Outlines Its Criticisms of the Tax Court’s Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners Understanding New Clean Electricity Credit Termination Rules Impact of IRS Notice 2025-42 on Wind and Solar Facilities  

This week we look at: Urgent Guidance Requested on Section 174A Domestic Research and Experimental Expenditures Post-Referral Authority in Tax Litigation—IRS Lacked Authority to Approve ERC Refund Closer This Time, But Still Not Quite There—Another Microcaptive Loss for the Taxpayers Proposed Amendments to IRC Section 132 Fringe Benefit Rules: Switching to NAICS Understanding Passthrough Losses and Bankruptcy in Field Attorney Advice 20253101F Proactive Engagement with the Office of Professional Responsibility IRS Announces Policy for the One Big Beautiful Bill Act for 2025 Payroll Issues