Federal Tax Update Podcast

This week we look at: Relief from Ineffective S Corporation and QSub Elections Procedural and Jurisdictional Limits in Challenging IRS Guidance Medicaid Gross Receipts, Cohan Estimations, and Professional Reliance Standards and Deceit in Supervised Release Transitional Guidance on Qualified Opportunity Zones

This week we look at: Proposed Increase to Estate Tax Closing Letter User Fee Divergent Causation Standards for ERC Eligibility Valuation Extremes in Conservation Easements Substantiating Mortgage Interest Deductions Taxation of Cryptocurrency Staking Rewards Section 4960 and "Covered Employees" FBAR Compliance and IRS Agent Authority

This week we look at: Equitable Relief for Erroneous Tax Refunds: An Analysis of the Fourth Circuit's Reversal in LaRosa v. Commissioner Final Regulations Modify Information Reporting for Section 751(a) Partnership Interest Exchanges The Impermeable Reach of Section 6672: Joint and Several Trust Fund Liability and the Demise of the Delegation Defense The Taxpayer Due Process Enhancement Act (H.R. 6506): A Crucial Legislative Response to Commissioner v. Zuch Demystifying Notice 2026-33: Comprehensive Guidance on Qualified Long-Term Care Distributions under the SECURE 2.0 Act IRS Action on Decision: Decoding the Service's Limited Acquiescence on Mandatory COVID-19 Postponements and the Road Ahead in Kwong

This week we look at: Syndicated Conservation Easements and the Valuation Conundrum: An Analysis of T.C. Memo. 2026-36 Analysis of Garcia-Rojas v. Franchise Tax Board: The Limits of the Unitary Business Doctrine for Sole Proprietors An Analysis of the Reinstated Significant Issue Letter Ruling Program Under Revenue Procedure 2026-21 The "Byers Rule" and the Administrative Procedure Act Jurisdictional Time Bars and the Timely Mailing Rule: An Analysis of Dunlap v. United States Temporary Import Surcharges and Executive Authority: A Review of the Court of International Trade's Ruling

This week we look at: Tax Implications of the Rescheduling of State-Licensed Medical Marijuana Disallowance of COVID-19 Leave Credits: A Review of Substantiation and Trade or Business Requirements The Tenth Circuit Codifies the Reach of the Economic Substance Doctrine Over Mechanical Statutory Compliance Substantiation, Entity Indebtedness, and Business Expense Deductibility: An Analysis of the Simmons Case Treatment of Loyalty Rewards Program Funds and the Claim of Right Doctrine Valuation and Penalty Controversies in Estate Tax Examinations

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: 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: 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: 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: 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: 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: 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: 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