Federal Tax Update Podcast

This week we look at: Zero-Return Form 1065 Filings and the Beard Test (IRS CCA 202634014) Full Payment Rule & Presumption of Correctness -- Pellegrino v. United States Pro Rata Share Determinations Under OBBBA -- Proposed Regulations (REG-115646-25) Treaty Exclusivity for Pooled Investments -- South Saskatchewan Community Foundation v. U.S.

This week we look at: Unpacking the Saver's Match: Technical Guidance and Operational Frameworks Under Notice 2026-48 Harmonizing Section 3406 Backup Withholding with Section 6050W De Minimis Reporting Thresholds The High Bar for Equitable Tolling in Tax Practice: The Eighth Circuit's Final Ruling in Boechler, P.C. Employer Contributions to Trump Accounts and Nondiscrimination Rules under REG-101355-26 The Perpetual Burden of Carryover Substantiation: AMT Credits and Recordkeeping in Beacom v. Commissioner Equitable Tolling of Tax Court Filing Deadlines: Maniktala v. Commissioner (8th Cir.) Standardizing Retirement Plan Rollovers and Trustee-to-Trustee Transfers under SECURE 2.0: Notice 2026-49 Unmasking the $70 Million Dubai Fraud: Section 165 Theft Loss Deductions in Deutsch v. Commissioner Treasury Proposes Substantive Section 987 Relief for Controlled Foreign Corporations (REG-103844-26) Rehearing Reversal: The Fifth Circuit's Management Test for the Limited Partner Exception (K Alain, L.L.L.P.) The Crucial Role of Highest and Best Use in Conservation Easement Valuations: Evans v. Commissioner

This week we look at: Valuation of Remainder Interest Gifts Upon Trust Termination: State Law and Net Gift Adjustments in Lewis v. Commissioner Revenue Procedure 2026-26: Technical Overview of 2027 Indexing Adjustments for Premium Tax Credits and Affordability Standards Limitations of Interest Abatement Claims Under I.R.C. § 6404(e)(1) in the Context of ERC-Driven Amendments Section 6015(c) Relief and the Substantiation Trap: An Analysis of Anderson v. Commissioner Navigating the AICPA's New Tax Services Independence Standards: A Guide for Practitioners

This week we look at: Reasonable Cause Relief Under the Small-Corporation Provision for Form 5472 Penalties Extending the Statute of Limitations for Disallowed ERC Claims Legislative Update: House Passes Comprehensive Tax Administration and Relief Bills Anticipated IRS Guidance Following the Rescheduling of Medical Marijuana Analysis of the New Dyed Fuel Excise Tax Refund Regulations Under Section 6435 Executive Order on Retirement Savings and Its Interaction with IRC Section 6433

This week we look at: A Technical Analysis of the Final Section 224 Regulations on the Qualified Tip Deduction Analysis of Proposed Regulations on Information Reporting Thresholds and Wagering Losses (REG-113229-25) U.S. District Court Splits Its Ruling on Micro-Captive Disclosure Mandates IRS Reduces Enrolled Agent Special Enrollment Examination User Fees: An Analysis of the Interim Final and Proposed Regulations Taxation of Terminated Life Insurance Policies: An Analysis of Constructive Receipt and Investment Interest

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: 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: 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.