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
Direct download: 2025-09-02a_Better_Late_Than_Never_RE_Procedural_Relief.mp3
Category:general -- posted at: 12:07pm EST

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
Direct download: 2025-08-25_Stump_the_LLM.mp3
Category:general -- posted at: 11:49am EST

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

 

Direct download: 2025-08-18_State_Tax_Credit_SALT_Workaround_Regulation_Challenge_Fails.mp3
Category:general -- posted at: 1:12pm EST

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
Direct download: 2025-08-11_IRS_Announces_No_Payroll_Changes_for_2025.mp3
Category:general -- posted at: 12:47pm EST

This week we look at:

  • Filing Season Forecast to Start in Mid-February in the Coming Season
  • Settlement Proceeds Found to Be Taxable and Taxpayer Stuck With Late-Filing Penalties
  • IRS Issues Relief for Certain Issues Related to Partnership Investments and the Corporate Alternative Minimum Tax
  • Corporate Mergers and the Same Taxpayer Rule for Interest Netting
  • What Is an Educational Organization for Unrelated Business Income Tax (UBIT) Purposes?
  • Another Microcaptive Arrangement Falls Under Court Challenge
  • Taxpayer’s Claim She Didn’t Consent to the Filing of a Joint Return Didn’t Impact Denial of Innocent Spouse Relief
Direct download: 2025-08-04_A_Late_Tax_Season_Start_Expected.mp3
Category:general -- posted at: 9:04am EST

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