2025-11-03 Qualifying Offers in Tax Disputes

This week we look at USPS Changes to Postmark Date System H.R. 1491: Disaster Related Extension of Deadlines Act Capitalization Priorities: Temnorod v. Commissioner Notice 2026-5: HSA Expansion Under OBBBA Fulfillment by Amazon (FBA) and "Doing Business" Substantiation Failures: Mirch v. Commissioner

This week we look at: Notice 2025-68 – Implementation of Trump Accounts Draft Form 4547 – Elections and Filing Mechanics Notice 2025-70 – The OBBBA Scholarship Tax Credit Alioto v. Commissioner – Corporate Distinctness

This week we look at: Innocent Spouse Relief Determination Standards Adjustments to Medicare Parts A, B, and D Equitable Distribution vs. Alimony (Pre-TCJA) Implementation of the Section 139L Interest Exclusion OBBBA Deductions for Tips and Overtime Compensation for 2025 returns

This week we look at: Annual Adjustments to Retirement Plan Limitations Ensuring Investment Trust Status for Digital Asset Staking Entities Examining Penalties in Microcaptive Transactions Ownership Requirements for Non-Business Theft Losses Defining the Scope of I.R.C. § 172(b)(3) Carryback Waivers

This week we look at: Conservation Easement Valuation and Highest and Best Use Trust Fund Recovery Penalty (TFRP) Application California Residency and Taxpayer Burden of Proof OBBBA Information Reporting Transition Relief SCOTUS Oral Argument on IEEPA Tariffs Conservation Easement Timing and Penalties Digital Asset Broker Reporting FAQ Guidance

This week we look at: Private Inurement and Operational Failure Prevailing Party Status Under § 7430 The Federal Priority Statute and Corporate Officer Liability Termination of the Automatic Stay in Bankruptcy Injunction Violations and Civil Contempt for Tax Preparer A Refined Approach to Math Error Notices Application of Unstated Interest Rules to Corporate Mergers

This week we look at: Reevaluating the DC-QIE Exception (FIRPTA) Technical Revisions to Revenue Procedure 2025-32 Transitional Reporting for Qualified Passenger Vehicle Loan Interest (QPVLI) Jurisdictional Clarity for TEFRA Readjustment Petitions S Corporation Income Attribution and Substantiation Failures IRS Operations During a Lapse in Appropriations Employee Retention Credit Compliance (OBBBA) Form 1099-K Information Reporting Updates

This week we look at: Employee Retention Credit Refunds in Bankruptcy Lawsuit Settlement Enforcement and Tax Disclosure Obligations Operational Test Failure: Commercial Activities and Private Benefit IRS E-File Suspension Authority Taxation of International Investment Losses Collection Due Process Analysis

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)