Latest US Tax Court decisions and federal tax court opinions
The IRS has approved a proposed corporate restructuring as a tax-free spin-off under Section 355 and Section 368(a)(1)(D) of the Internal Revenue Code, according to a recently issued private letter ruling (PLR-119258-25).
9100-3 to four taxpayers (A, B, C, and D) who inadvertently missed the deadline to file Form 8832, the entity classification election to be treated as disregarded entities.
9100-3 to a taxpayer seeking to elect Qualified Subchapter S Subsidiary (QSub) status for a subsidiary, allowing the election to be effective as of Date 2. The taxpayer must file Form 8869 with the appropriate service center and include a copy of this Private Letter Ruling (PLR-116311-25).
The IRS granted a 120-day extension to file Form 8832 to retroactively elect disregarded entity status, despite the taxpayer’s $0 cost mistake. 9100-3.
A taxpayer’s complex web of trusts—designed to benefit descendants—accidentally triggered $10 million-plus in unintended GST exemption allocations after professional advisors failed to recognize the automatic allocation rules under Section 2632(c)(1) of the Internal Revenue Code.
The IRS has issued a favorable private letter ruling (PLR-113827-25) blessing proposed modifications to a pre-1985 irrevocable trust, confirming four critical tax outcomes: the trust’s continued exemption from generation-skipping transfer (GST) tax under § 2601, the absence of a...
The IRS ruled in PLR-113817-25 that a partnership’s receipt of diversified investment assets would not trigger gain recognition under § 721(a), despite the partnership’s potential status as an investment company under § 721(b).
D. 10048 that streamline information reporting obligations for partnerships selling certain partnership interests. Effective immediately, partnerships are no longer required to furnish computational information to partners by January 31 of the year following the sale or exchange.
The Tax Court granted summary judgment in favor of the IRS, upholding deficiencies and penalties exceeding $250,000 for tax years 2011–2013 against serial tax evader Adam Shryock. The ruling bypassed trial entirely due to Shryock’s failure to contest critical allegations.
In Fuhai Li and Hong Hu v. S. Tax Court addressed the interplay between criminal convictions and civil tax fraud penalties. The IRS assessed deficiencies of $292,170 and fraud penalties of $225,877 under Section 6663 for tax years 2011–2013. The court ruled that Mr.
S. Tax Court delivered a stark reminder to taxpayers on May 27, 2026, when it upheld a $22,383 deficiency against Sang Hun Lee after he failed to substantiate claimed business expenses. The court’s ruling—issued in Lee v. C. Memo.
7701-3, to retroactively be treated as a corporation for federal tax purposes. The IRS granted the extension, though the ruling remains non-precedential.
9100-3 of the Procedure and Administration Regulations. 9100-3 provides discretionary relief for regulatory elections filed outside prescribed deadlines. The effective dates for both elections remain unchanged, preserving the taxpayer’s intended tax treatment retroactively.
The IRS has approved a proposed transaction where an S corporation (Distributing) spun off a subsidiary (Controlled) to a shareholder (Shareholder D) in exchange for their stock in Distributing.
The IRS granted § 9100 relief to a taxpayer who missed the deadline to self-certify as a Qualified Opportunity Fund (QOF) for Year 1, allowing retroactive certification after a miscommunication between the taxpayer’s controller and tax advisor led to the omission of Form 8996.
9100-3 for a partnership to file a late § 754 election after the partnership inadvertently missed the deadline due to oversight.
The IRS ruled in favor of the taxpayer on all four requested rulings, allowing the surviving spouse to treat the IRA proceeds as her own and roll them over into her own IRA within 60 days.
The IRS has ruled that periodic payments under an indexed structured settlement annuity contract meet the "fixed and determinable" requirement of § 130(c)(2)(A) and qualify as a "qualified funding asset" under § 130(d).
The IRS has ruled that indexed structured settlement annuities—contracts with payments tied to market performance but featuring a guaranteed minimum—can qualify as "qualified funding assets" under § 130 of the Internal Revenue Code.
The Internal Revenue Bulletin (IRB) No. 2026–22, issued May 26, 2026, delivers a sweeping array of administrative, procedural, and legislative updates that will reshape tax compliance, planning, and enforcement for practitioners across industries.
The stakes could not have been higher for Bryan Edward Menge.
The Internal Revenue Bulletin (IRB) 2026–21, published on May 18, 2026, delivers a significant regulatory adjustment that will resonate across the tax profession: the IRS has slashed the user fee for the Special Enrollment Examination (SEE) required to become an enrolled agent...
9100-3 to an estate that missed the deadline to elect portability of the deceased spouse’s unused estate tax exclusion (DSUE). 61 million per individual in 2024—thereby reducing future estate tax liability.
9100-3—which allows taxpayers to request discretionary relief for missed regulatory elections—for a parent company that failed to timely file a consolidated return election for its affiliated group.
9100-3 to a taxpayer who missed the 60-day deadline to file a § 336(e) election, allowing a stock sale to be treated as an asset sale for tax purposes. 336-1(b)(6).
The IRS has issued a non-precedential private letter ruling (PLR-112873-25) approving the use of indexed structured settlement annuities under § 130(c)(2)(A) of the Internal Revenue Code.
The Martins’ $332,500 charitable contribution deduction—a sum large enough to erase nearly a third of their 2018 tax liability—vanished in a single stroke when the Tax Court ruled their substantiation documents failed to include a single, mandatory sentence. The case, Martin v. C. Memo.
The stakes could not have been higher when the Martins claimed a $339,400 charitable deduction on their 2018 return—one of the most scrutinized figures in Tax Court history.
The Internal Revenue Service’s release of Rev. Proc. 2026-14 marks a seismic shift in the Opportunity Zones (QOZ) program, fundamentally altering the landscape for economically distressed communities seeking investment incentives.
7701-3. The relief allows the election to be effective as of the originally intended date, providing certainty for the taxpayer’s tax treatment. Taxpayers facing similar late-filing situations may seek analogous relief under the same provision.
The IRS granted relief to X Corporation, allowing its late S corporation election to be treated as timely filed under Section 1362(b)(5) of the Internal Revenue Code.
The IRS has revoked Private Letter Ruling 201949002, issued in 2019, which addressed whether accounting method changes could generate additional § 48 investment tax credits for qualifying energy property.
The IRS granted relief under § 1362(f) to an S corporation whose status inadvertently terminated after a trust failed to timely elect Electing Small Business Trust (ESBT) status under § 1361(e), causing the trust to become an ineligible shareholder.
9100-3 to an S corporation’s shareholders and purchaser, permitting a late §336(e) election after missing the original deadline tied to the target’s tax return due date.
A partnership’s failure to file a § 754 election—a critical tax mechanism that adjusts asset bases to reflect a partner’s death—could have triggered a $1M+ tax liability in unrealized gains. 9100-3, sparing the partnership from costly missteps.
The IRS granted a 45-day extension to a partnership to file its Form 3115 after its CPA inadvertently failed to upload the required application to the taxpayer’s timely filed federal income tax return.
The IRS granted permission for X to re-elect S corporation status effective Date 3—prior to the expiration of the five-year waiting period under Internal Revenue Code § 1362(g)—after C acquired 100% of X’s interests from A and B on that date.
The IRS granted a 120-day extension to a limited liability company (LLC) to file Form 8832, Entity Classification Election, after the taxpayer missed the 75-day retroactive window to elect corporate tax treatment. 7701-3.
A $5 million-plus estate faced imminent estate and generation-skipping transfer (GST) tax liabilities after an accountant erroneously filed Form 706, misclassifying QTIP property and triggering a failed QTIP election.
The IRS ruled in PLR-113278-25 that proposed modifications to an irrevocable trust executed prior to September 25, 1985, would not trigger a taxable event under the Generation-Skipping Transfer (GST) Tax, nor would they result in estate or gift tax implications for the grantor or beneficiaries.
The IRS issued Private Letter Ruling PLR-113277-25, confirming that modifications to an irrevocable trust established before September 25, 1985, will not jeopardize its GST tax-exempt status or trigger estate or gift tax consequences. The ruling addresses four key questions: 1. 2601-1(b)(4). 2.
The IRS has ruled that proposed modifications to a pre-September 25, 1985 irrevocable trust will not jeopardize its generation-skipping transfer (GST) tax-exempt status, provided the changes comply with regulatory safe harbors.
The IRS ruled that proposed modifications to an irrevocable trust created before September 25, 1985—with no post-1985 additions—would not jeopardize its generation-skipping transfer (GST) tax exempt status, trigger estate tax inclusion for the grantor, or create gift tax...
The IRS has issued a favorable private letter ruling (PLR-113274-25) affirming that proposed modifications to an irrevocable trust will not jeopardize its generation-skipping transfer (GST) tax exempt status.
The IRS ruled favorably in PLR-113273-25, granting four requested rulings regarding proposed modifications to an irrevocable trust created before September 25, 1985.
The IRS has issued a rare lifeline to an S corporation whose election was inadvertently terminated after trust shareholders failed to make required Qualified Subchapter S Trust (QSST) or Electing Small Business Trust (ESBT) elections.
The IRS granted relief under Section 1362(f) to an S corporation whose election terminated when a trust failed to timely elect Electing Small Business Trust (ESBT) status, concluding the termination was inadvertent.
1 million tax bill from the IRS—one that threatened to upend his life and business. At the heart of the dispute was a $2 million offer-in-compromise (OIC) Joseph submitted to settle his tax liabilities for 2011 through 2017, along with a $100,000 installment agreement (IA) request.
The Tax Court just handed the IRS a $30 million victory—and a warning shot to promoters of syndicated conservation easements.
S. Tax Court issued its ruling in Kimberly Road Fulton 25, LLC v. Commissioner and South Fulton Parkway 58, LLC v. Commissioner on May 4, 2026. 5% of what the taxpayers sought. The IRS had argued for total disallowance, while the partnerships claimed the full $30 million was justified.