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Sevillo Fine Foods LLC v. United States, Case No. 2:25-cv-00273-DBP, 2026 U.S. Dist. LEXIS _____ (D. Utah Sept. 28, 2026) As tax practitioners evaluating Employee Retention Credit (ERC) refund claims, CPAs and Enrolled Agents (EAs) face heightened scrutiny from both the Internal Revenue Service and federal courts regar
Trump Accounts, 91 Fed. Reg. 63200 (Sept. 30, 2026) (TD 10056); Trump Accounts, 91 Fed. Reg. 63215 (proposed Sept. 30, 2026) (CC-00226466-26) The Department of the Treasury and the Internal Revenue Service have jointly issued temporary regulations (Treasury Decision 10056, RIN 1545-BS27) and a concurrent notice of prop
Amodio v. Commissioner, T.C. Memo. 2026-96, Docket No. 9959-22L (Sept. 28, 2026) For tax controversy practitioners, Certified Public Accountants, and Enrolled Agents, navigating the personal liability provisions of Internal Revenue Code (I.R.C.) § 6672 requires a precise understanding of the statutory standards for “wi
Rev. Rul. 2026-20, 2026-20 I.R.B. 1, September 28, 2026 Notice 2026-62, 2026-20 I.R.B. 1, September 28, 2026 In a coordinated regulatory release, the Department of the Treasury and the Internal Revenue Service issued Revenue Ruling 2026-20 alongside Notice 2026-62 to address what tax administrators describe as “novel i
Notice of Proposed Rulemaking, Election to Pay in Installments Tax on Gain from Certain Farmland Property, REG-117095-25, 91 Fed. Reg. 63812 (proposed Sept. 29, 2026) The Department of the Treasury and the Internal Revenue Service have issued proposed regulations (REG-117095-25) implementing Internal Revenue Code (IRC)
Juliet R. Singh v. United States, No. 1:25-cv-00056 (E.D.N.Y. Sept. 24, 2026) Tax practitioners frequently encounter situationally complex client cases where taxpayers, acting without immediate legal or tax counsel, submit informal written requests to the Internal Revenue Service (IRS) explaining economic hardships or
Jagannath v. Commissioner, T.C. Memo. 2026-92 (Sept. 24, 2026) In Jagannath v. Commissioner, T.C. Memo. 2026-92 (Filed September 24, 2026), the United States Tax Court addressed the application of section 4958 intermediate sanctions excise taxes to an uncorrected transaction between a Section 501(c)(3) public charity a
Lindsey v. Commissioner, T.C. Memo. 2026-94 (Sept. 24, 2026) In federal tax controversy practice, few procedural hurdles carry as much consequence as the mailing of a Statutory Notice of Deficiency (SNOD) under Internal Revenue Code (I.R.C.) § 6212 and the strict 90-day jurisdictional petition window mandated by I.R.C.
Notice 2026-60, 2026-41 I.R.B. 1, Sept. 23, 2026 On an annual basis, the Internal Revenue Service releases administrative guidance updating the special per diem rates and list of high-cost localities utilized by taxpayers to substantiate ordinary and necessary business travel expenses. Notice 2026-60 serves as the offi
Treasury Decision 10055, RIN 1545-BS10, Sept. 25, 2026 The Department of the Treasury and the Internal Revenue Service (IRS) have issued Final Regulations (Treasury Decision 10055, RIN 1545-BS10) amending 26 CFR Part 300 to increase the user fee charged to authorized persons requesting IRS Letter 627, commonly referred
Williams v. Commissioner, T.C. Memo. 2026-91, (Sept. 23, 2026) This analysis examines Williams v. Commissioner, T.C. Memo. 2026-91, a United States Tax Court decision evaluating the disallowance of significant personal casualty loss deductions, noncash charitable contributions, state and local tax (SALT) deductions, an
IRS Notice 2026-55, 2026-41 I.R.B. 1 (Sept. 2026). The Department of the Treasury and the Internal Revenue Service issued Notice 2026-55 in Part III of the Internal Revenue Bulletin to request formal public and professional commentary regarding complex administrative and legal issues under Section 1400Z-2 of the Intern
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