news• US Tax Court
Novak v. Commissioner: Tax Court Upholds IRS Lien Despite Multi-Million-Dollar Installment Agreement Dispute
The Tax Court’s June 17, 2026 ruling in Novak v. C. Memo.
Docket No. 7365-24L
The Tax Court’s June 17, 2026 ruling in Novak v. C. Memo.
3 million tax deficiency for tax years 2015 through 2017. The IRS, acting under Section 6020(b), prepared substitutes for returns (SFRs) after Branch failed to file, estimating over $6 million in annual gross receipts for her sole proprietorship.
S. 41-4A(d)(3). The court rejected the IRS’s attempt to fully disallow the credits but also rejected the taxpayers’ argument that the Supreme Court’s 2024 decision in Loper Bright Enterprises v. Raimondo invalidated the funded research regulations under Section 41(d)(4)(H).
The IRS Bulletin No. 2026–25, released June 15, 2026, introduces four major updates reshaping tax planning for health savings accounts (HSAs), broker-dealer compliance, foreign government taxation, and energy sector incentives.
The IRS granted a 120-day extension for a late § 754 election after a State limited partnership inadvertently failed to file the election following a partner’s death. 9100-3, allowing the partnership to retroactively elect to adjust the basis of its property under § 754 of the Internal Revenue Code.
The IRS granted relief under Section 1362(f) to an LLC that inadvertently failed to qualify as an S corporation due to its operating agreement and profits interests violating the one-class-of-stock rule under Section 1361(b)(1)(D).
The IRS has approved a taxpayer’s request to aggregate separate nonoperating mineral interests under Section 614(e) of the Internal Revenue Code, allowing the interests to be treated as a single property for depletion calculations.
9100-3 to a taxpayer seeking to elect qualified subchapter S subsidiary (QSub) status under § 1361(b)(3) after inadvertently failing to file Form 8869 within the required deadline.
A taxpayer faced a potential $10 million tax liability after an internal miscommunication led to a missed deadline for critical elections tied to bonus depreciation and R&D expenditures.
The IRS has issued a non-precedential Private Letter Ruling (PLR) granting three critical tax rulings for a public health settlement trust: (1) the trust qualifies as a qualified settlement fund (QSF) under § 1.
The IRS confirmed in a Private Letter Ruling (PLR) that an inherited IRA can be divided into separate accounts for multiple beneficiaries without triggering immediate tax consequences.
42 million charitable deduction claimed by William P. and Ruth E. Wells for tax years 2019–2021, resulting in $402,708 in deficiencies and penalties.
The Tax Court’s June 10 ruling in Aryanpure v. Commissioner exposes a staggering $500,000 in tax deficiencies and $375,000 in fraud penalties—underscoring the IRS’s relentless pursuit of medical professionals who blur the lines between personal and business finances.
The Tax Court’s June 9 ruling in Schumacher v. Commissioner denied $191,179 in deductions for 2017–2019 and upheld $33,520 in penalties for Keith and Rhonda Schumacher’s horse breeding operation.
1502-75(a)(1). The relief allows the affiliated group to file the election within 75 days of the ruling letter’s issuance, despite missing the original deadline tied to the taxable year’s extended return due date.
1502-75(a)(1), the regulation governing consolidated federal income tax returns. The taxpayer requested relief after missing the deadline to elect consolidation for the taxable year ending on Date 1, citing reasonable action and good faith in its compliance efforts.
The IRS granted relief to married taxpayers who inadvertently elected out of the installment sale method due to a preparer’s oversight, allowing them to revoke the election and report the gain proportionally over time.
The IRS has issued a non-precedential Private Letter Ruling (PLR-117459-19) clarifying that loans between a REIT and its joint ventures—when attributable to the REIT’s capital interest—are excluded from the REIT’s asset tests under § 856(c)(4).
The IRS granted a 120-day extension for a late § 754 election in a non-precedential private letter ruling (PLR-117052-25), permitting a partnership to retroactively adjust asset bases after a partner’s death.
7701-3, allowing the taxpayer to retroactively elect corporate tax treatment and S corporation status.
9100-3. The partnership failed to make the election due to its tax advisors overlooking the requirement, leaving it unable to adjust basis following the partner’s passing—a critical omission given the potential for double taxation.
The IRS granted a rare 120-day extension for a late § 754 election after a partnership missed the filing deadline due to an advisor's oversight and the death of a partner. In a non-precedential ruling, the agency concluded the partnership acted reasonably and in good faith, despite the omission.
A corporation’s attempt to retroactively claim $5 million in securities trading losses under the mark-to-market accounting method was rejected by the IRS, which ruled the taxpayer acted with impermissible hindsight.
The IRS granted a consolidated group a rare extension to file late elections under Treas. Reg. 1502-14Z(c)(2), allowing the group to retroactively treat investments in Qualified Opportunity Funds (QOFs) as qualifying deferral elections under § 1400Z-2.
9100-3 to a taxpayer who missed the deadline for self-certifying as a Qualified Opportunity Fund (QOF) under § 1400Z-2(d). The taxpayer requested an extension to file Form 8996, the IRS-required certification mechanism for QOFs, and the IRS ruled that the late filing would now be treated as timely.
The IRS granted an extension to file a Section 336(e) election after the taxpayer requested relief under Treas. Reg. 9100-3 for a late filing. The agency concluded the parties acted reasonably and in good faith, waiving the late election penalty.
S. citizen before the estate’s administration concluded. The ruling preserved a $X million marital deduction that would have otherwise been lost due to the late conveyance of trust assets.
The IRS granted late election relief to an S corporation seeking to change its tax year-end after missing the filing deadline for Form 1128, the application to adopt, change, or retain a tax year.
The IRS has issued a final ruling denying tax-exempt status for two specialized military vehicles, potentially exposing defense contractors to a 12% federal excise tax (FET) on their first retail sales.
The IRS granted a non-precedential private letter ruling (PLR-110907-25) extending the deadline for a surviving spouse to elect qualified domestic trust (QDOT) treatment under § 2056A(d) after her tax professional failed to advise her of the Form 706 filing requirement. S. citizen spouse.