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The IRS granted a 120-day extension to make a qualified terminable interest property (QTIP) election under § 2056(b)(7) after the executor of a decedent’s estate discovered an error on Schedule M of Form 706, the federal estate tax return.
The IRS granted inadvertent termination relief under § 1362(f) to a corporation that inadvertently invalidated its S election due to an ineligible shareholder and a second class of stock.
A Real Estate Investment Trust (REIT) stood to lose a $a capital gain deduction in Year 1 when a dividend declared in Year 2 was mistakenly omitted from its timely filed tax return.
The IRS granted relief under § 1362(f) to an S corporation whose election terminated after ineligible trusts failed to file Electing Small Business Trust (ESBT) elections under § 1361(e).
On August 20, 2026, the IRS issued a private letter ruling (PLR-118845-25) confirming that a state university’s partnership with a biopharmaceutical firm to develop radioisotopes for life-threatening diseases does not trigger unrelated business income tax (UBIT).
The IRS granted a 120-day extension to a taxpayer seeking to file an amended Form 8609 to correct a missed average income election under Section 42(g)(1)(C) of the Internal Revenue Code, preserving potential low-income housing credits exceeding $5 million over the 10-year credit period.
Stay updated with the latest tax court analysis, featured articles, and news posts.
The IRS's strategy to combat tax shelters is facing a pincer movement. While Mann and Green Valley forced the agency to use formal regulations, the Ryan challenge now threatens to invalidate those very regulations as arbitrary and capricious.
Four recent federal court cases—Mukhi, Silver Moss, Riddle Aggregates, and Schwarzbaum—refine the boundaries of tax penalties, balancing IRS authority against constitutional protections and statutory limits in areas like international reporting, conservation easements, and foreign bank accounts.
The Trump Administration's 2025 cryptocurrency tax framework represents a comprehensive approach to promoting innovation while reducing regulatory barriers, prioritizing individual freedom and self-custody by removing rules that make cold storage and direct ownership of digital assets difficult.
2026 will likely see dramatic re-adjustments to the balance of federal authority with serious implications for the IRS
In a landmark reversal, the Eighth Circuit ruled that the IRS cannot tax income that a taxpayer is legally prohibited from receiving, delivering a major blow to the agency's reallocation authority under Section 482.
An in-depth examination of criminal tax cases involving cryptocurrency and digital assets, including prosecution arguments, defense strategies, and unique case facts. This resource aggregates all known criminal tax prosecutions related to cryptocurrency.
We welcome submissions from tax attorneys for featured articles, case analyses, and commentary on US Tax Court decisions and tax jurisprudence.
Send submissions to: david@newmanbrunk.com
The Tax Court Blog provides in-depth US tax court analysis, expert commentary on IRS court cases, and insights for tax professionals and taxpayers.
Understanding the critical distinction between grantor and non-grantor trusts, their tax consequences, and the factual elements that determine classification. This guide explores the tradeoffs between tax treatment and asset protection.
Understanding Intentionally Defective Grantor Trusts (IDGTs), their purpose in estate planning, and how they are structured to achieve both estate tax exclusion and income tax advantages while maintaining asset protection benefits.
Understanding the critical tradeoffs between probate avoidance, estate tax minimization, and basis step-up benefits in trust and estate planning. This guide explores how different strategies balance these competing objectives.
Exploring the emerging intersection of blockchain technology, smart contracts, and trust law. This guide examines how wallet addresses can serve as trust identities, hardware security modules (HSMs) as trustees and beneficiaries, and the tax treatment and asset protection possibilities in the digital asset era.
Tax credit and exclusion for qualified adoption expenses
Tax treatment of alimony payments and separate maintenance payments
Deductions for ordinary and necessary business expenses under Section 162
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