Latest US Tax Court decisions and federal tax court opinions
752-2(b), which defines economic risk of loss for partnership liabilities. 704-1(b)(2)(ii)(c)(1). This ruling underscores the IRS’s strict scrutiny of conditional obligations in partnership agreements, particularly for private equity and hedge funds structuring capital account terms.
The IRS granted late election relief under § 1362(b)(1)—which allows S corporation status to be elected retroactively when a taxpayer fails to file Form 2553 on time—to a corporation that inadvertently missed the deadline.
9100-3. The IRS’s decision hinged on the taxpayer’s accountant’s failure to file Form 7004, an automatic extension request, due to internal oversight.
7701-3. 9100-3, which allow the IRS to extend deadlines for regulatory elections when the taxpayer acted reasonably and in good faith, and the government’s interests would not be prejudiced.
A wealthy family nearly lost $3 million in Generation-Skipping Transfer (GST) tax exemption after attorneys and accountants failed to allocate the exemption during three consecutive years of trust transfers.
1502-75(a)(1)—despite filing nearly a year late—after the taxpayer demonstrated reasonable reliance on a tax professional’s oversight.
9100-3 to a taxpayer who missed the deadline to file a §336(e) election, allowing a stock sale to be treated as an asset disposition. 336-2(h)(3)(iii). The IRS’s decision hinged on the taxpayer’s reasonable reliance on professional advice and lack of prejudice to government interests.
The IRS granted a REIT’s request for a late election under Section 856(l) of the Internal Revenue Code to treat its subsidiary as a Taxable REIT Subsidiary (TRS), effective as of Date 3.
9100-3 of the Procedure and Administration Regulations, allowing a taxpayer to file Form 8832 retroactively to elect disregarded entity status. 7701-3, which governs the "check-the-box" rules for tax classification.
The Internal Revenue Bulletin No. 2026-29 introduces sweeping changes to energy tax credits, environmental taxes, and compliance requirements that demand immediate attention from tax practitioners.
S. Tax Court ruled on July 8, 2026, that the IRS had the power to correct its own mistakes—without filing a lawsuit. , after the IRS admitted it had miscalculated the company’s tax liability and issued an erroneous refund. The court’s ruling in Hough Beck & Baird, Inc. v. Commissioner, Docket No.
Thermal Circuits, Inc. just learned the hard way that the Tax Court will not rewrite the rules on customer-funded leasehold improvements—even when the customer is a $5 billion tobacco giant.
The Tax Court’s ruling in Dee delivers a dual message: a jurisdictional win for whistleblowers and a sharp reminder of the IRS’s unassailable discretion. After a decade-long battle, John R.
The Internal Revenue Bulletin No. 2026-28, issued July 6, 2026, delivers three pivotal updates reshaping pension funding calculations, federal rate applications, and Qualified Opportunity Zone (QOZ) compliance.
The IRS granted relief under § 1362(f) to S corporation X for an inadvertent failure to meet Qualified Subchapter S Subsidiary (QSub) election requirements.
The IRS granted a taxpayer’s request for a late election to be treated as a real estate investment trust (REIT) under Section 856(c) of the Internal Revenue Code, despite missing the initial filing deadline.
9100-3 to file late Form 8832, Entity Classification Election elections, allowing them to retroactively elect disregarded entity status. S. federal income tax returns consistent with their elected classification.
A CPA’s failure to properly elect Qualified Terminable Interest Property (QTIP) and reverse QTIP treatment on Form 706 nearly cost an estate $12 million in avoidable estate and GST taxes.
The IRS granted discretionary relief under § 1362(b)(1) of the Internal Revenue Code to a taxpayer who failed to timely file Form 2553 to elect S corporation status.
The IRS granted relief under § 1362(f) to an S corporation whose election terminated after its operating agreement inadvertently created multiple classes of stock, allowing the corporation to retain its S status.
The IRS has ruled that a proposed corporate spin-off qualifies as a tax-free reorganization under Sections 355 and 368(a)(1)(D) of the Internal Revenue Code, providing critical guidance for taxpayers navigating complex restructurings.
An S corporation faced potential tax liabilities exceeding $5 million after inadvertently missing deadlines to elect Qualified Subchapter S Subsidiary (QSub) status for four subsidiaries.
The IRS granted a taxpayer’s request for both an extension of time to make late Qualified Subchapter S Subsidiary (QSub) elections and relief for ineffective elections, allowing the company to avoid disqualification of QSub status for 10 subsidiaries.
The IRS granted a rare 120-day extension to a foreign company that missed the deadline to file Form 8832, the election to be treated as a disregarded entity for federal tax purposes.
The IRS granted a rare 120-day extension to a foreign company seeking to file a late Form 8832 election to be classified as a disregarded entity, citing the taxpayer’s reasonable and good-faith actions. 9100-3 are infrequent and the ruling carries no precedential weight.
The IRS granted a private foundation’s request to retroactively correct errors in treating leased property as both a qualifying distribution and exempt-use property under Section 4942, allowing the foundation to recompute its minimum investment return and qualifying distribution...
The IRS granted a 120-day extension to file Form 706, allowing a surviving spouse to claim the deceased spouse’s unused exclusion (DSUE) amount under § 2010(c)(5)(A).
The Tax Court’s decision in Edmund Ha v. 80 accuracy-related penalty for failing to meet the IRS’s strict substantiation requirements.
The Tax Court delivered a blunt reminder to high-earning entrepreneurs last month: $50,427 in claimed Schedule C deductions vanished into thin air after Gregory A. Rodrigues, a former CEO and real estate investor, failed to meet the IRS’s strict substantiation requirements. C.
S. 1 million in unpaid restitution-based assessments (RBAs) while a prior Department of Justice (DOJ) settlement was still in force. 89 million tax liability to judgment under a structured payment plan.