2026-01-19 Fifth Circuit Reverses Tax Court on SE Income for State Law Limited Partners

This week we look at: Fiduciary and Beneficiary Liability for Unpaid Estate Taxes Retroactive Entity Classification and Partnership Basis 2026 Passenger Auto Depreciation Limits Passport Certification & Victimization Defenses Passport Revocation in Collection Suits Waiver of Foreign Earned Income Exclusion Time Rules New Digital Asset Reporting Landscape (Form 1099-DA)

This week we look at: Required Minimum Distribution Regulations Delay CDP Proceedings and Underlying Liabilities Section 743(b) Adjustments and Economic Substance Assessability of Section 6038(b) Penalties

This week we look at: Supreme Court Invalidates Executive Tariffs Under IEEPA  Special Depreciation Allowance Under the OBBBA  CAMT Adjustments and Relief  Circuit Split on Third-Party Fraud  Valuation and Penalties in Syndicated Conservation Easements

This week we look at: TEFRA Jurisdiction and the "Limited Partner" Exception Artificial Intelligence and Substantiation Section 183 Profit Motive Rebate vs. Nonrebate Refunds Substantiation and Civil Fraud Consolidated Return Jurisdiction Copyright 2026, Thomas, Zollars & Lynch Ltd.

This week we look at: The "Charitable LLC" Tax Shelter Section 280E Bars ERC for Cannabis Businesses TEFRA Intervention by Majority Partners R&D Credit Substantiation Supervisory Approval of Penalties ERISA Beneficiary Designations

This week we look at: Challenging the Presumption of Delivery (CDP Cases) Bank Deposits & Conduit Theory Mandates Under Executive Order 14247 (Notice CP53E) IRS Implementation of Executive Order 14247 - (FS 2026-02) Federal Priority Statute Liability FASIT Structure & Substantial Compliance

This week we look at: ERC Refund Suits and Challenges to IRS Notice 2021-20 Section 6015(f) Equitable Relief and Attribution of Income Financial Disability Tolling under § 6511(h) Distinguishing "Tax Loss" for Sentencing vs. Restitution Implementation of Qualified Overtime Deductions (OBBBA)

This week we look at: SE Tax Liability for Limited Partners (Sirius Solutions) Whistleblower Awards and "Collected Proceeds" Statutory Construction of Section 168(k) Amendments Updated Safe Harbor Explanations for Section 402(f) Modernized Group Tax Exemption Framework Tax-Exempt Status of Supplemental Military Housing Allowances

This week we look at: Standard Mileage Rates & Notice 2026-10 2026 Procedural Updates - Annual Revenue Procedures Qualified Passenger Vehicle Loan Interest (QPVLI) Proposed Regulations Estate of Spenlinhauer v. Commissioner Late Filing and More Bargain Sale of For-Profit colleges to a Non-Profit (501(c)(3))

This week we look at: Executive Action on Marijuana Scheduling and IRC § 280E State Paid Family and Medical Leave (PFML) Programs Estimated Tax Relief for Qualified Farmland Sales IRC § 163(j) Interest Limitation Updates Premium Tax Credit (PTC) Revisions