Federal Tax Update Podcast

This week we look at: Corporate Capacity and State Law Revivor Digital Asset Identification Relief Interest and Bonus Depreciation Relief ERC Disallowances and Legal Standing Substantiation Rules for Emergency Vehicles Partnership Audits and Due Process Social Security Repayments

This week we look at: Proposed Regulations for IRC Section 530A "Trump Accounts" IRC Section 6434 Trump Account Pilot Program Micro-Captive Scrutiny Formalized BBA Audits: Notice Defects and the Statute of Limitations

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

This week we look at: Section 25F Advance Elections Unreported Income & The "Missing Witness" Constitutionality of Penalties Post-Jarkesy Section 280E & Offers-in-Compromise Substantiating Bad Debt & NOLs

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)

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