Federal Tax Update Podcast

This week we look at:

• Ninth Circuit rules that statute of limitations for the IRS to sue for recovery of erroneous refund begins when the check clears the Federal Reserve and is approved for payment by the US Treasury
• IRS National Taxpayer Advocate announces the IRS will automate FTA abatement of penalties beginning in 2026
• Attorneys report some ERC claimants now interesting in filing suit to accelerate their claim processing

This week we look at:

• Supreme Court rules, in a more divided than it may appear opinion, that the §965 transition tax is Constitutional, sustaining the result from the Ninth Circuit in the Moore case.
• IRS gives interim guidance for special distribution relief in the SECURE Act 2.0 for certain distributions.
• IRS indicates it will now be (slowly) processing ERC claims, vast majority show issues

This week we look at:

• IRS provides last minute relief for payment of second quarter corporate estimated tax payments related to corporate alternative minimum tax
• En-banc rehearing request denied in case of Farhy v. Commissioner by DC Circuit
• CPA pleads guilty to tax charges related to syndicated conservation easement program
• Taxpayer Advocate warns of relying on generative AI for answering tax questions for consumer tax software - and there are just as big of issues for tax professionals

This week we look at:

• US Supreme Court rules that a requirement to redeem the decedent’s shares cannot be considered to reduce the value of the entity, but life insurance proceeds received by the entity to fund the buyout will increase the value
• Taxpayer denied relief for late rollover when funds were accidentally transferred from employer plan to Roth IRA
• IRS rules certain payments related to East Palestine, Ohio derailment are §139 disaster payments
• What options exist for an employer with a pending ERC claim?

This week we look at:

• IRS announces that Direct File will continue into 2025 and be expanded while maintaining other programs
• A taxpayer finds its not so simple as just file a Form 2553 if you want to have an LLC taxed as an S corporation, but did realize the error fast enough to get a PLR to restore S status