A deceased taxpayer’s estate faced a $250,000+ tax liability after failing to report cancellation of debt income (CODI) from a partnership’s discharged indebtedness.
The IRS granted a 120-day extension to an LLC seeking relief for late filings of both Form 8832 (entity classification election) and Form 2553 (S corporation election), effective as of Date 2.
The IRS ruled that a transfer of assets between two private foundations controlled by the same individuals qualifies as a tax-free consolidation under Section 507(b)(2), avoiding termination tax liability and other excise taxes.
9100-3 to an LLC that missed the deadline to file Form 8832, the entity classification election form. The IRS permitted the LLC to retroactively elect corporate tax treatment, effective as of the originally intended date, provided the corrected filing is submitted within 120 days of the ruling.
A $3 million Generation-Skipping Transfer (GST) tax liability loomed over a family after their attorney failed to allocate exemption to trusts for their grandchildren—until the IRS granted a 120-day reprieve.
The IRS has issued a private letter ruling (PLR-111481-25) confirming that Township T’s deferred compensation plan qualifies as an eligible governmental deferred compensation plan under Section 457(b) of the Internal Revenue Code.
The IRS has reversed its prior position in PLR 202426001, retroactively reinstating the income deferral rule from PLR 201424014.
9100-3 to a taxpayer seeking to make a late election under § 168(h)(6)(F)(ii) to avoid treatment as a tax-exempt entity. The IRS ruled that the taxpayer acted reasonably and in good faith by relying on a qualified tax advisor, and that granting relief would not prejudice the government’s interests.
The July 27, 2026 Internal Revenue Bulletin introduced three major developments reshaping tax planning for charitable trusts, life insurance transactions, and health insurance subsidies. Rev. Proc.
The Tax Court’s July 22 decision in Anderson v. C. Summary Opinion 2026-6) delivers a rare victory for a taxpayer seeking innocent spouse relief, awarding relief under Section 6015(c) and rejecting the IRS’s claim of actual knowledge.
The Tax Court’s July 21 ruling in Matto v. C. Memo.
The Tax Court’s latest ruling in Beveled Edge Insurance Company, Inc. v. C. Memo.
The Tax Court just handed down a ruling that could reshape how families unwind trusts—and how much they owe in gift tax. In a pair of decisions filed today, Linda M. Lewis, Donor, Petitioner v. Commissioner of Internal Revenue and Peter F. McDougall, Donor, Petitioner v. C. Memo.
S. C. Memo. 2026-59, it closed the door on a taxpayer’s last chance to challenge a $36,594 levy notice for tax year 2016.
The latest Internal Revenue Bulletin contains two critical updates that will significantly affect tribal governments, tax practitioners, and filers of information returns.
The IRS granted a 45-day extension to a taxpayer who filed Form 3115, Application for Change in Accounting Method, after the statutory deadline, preserving a $481(a) adjustment recorded on its return.
The IRS granted a taxpayer’s request for an extension to make a late § 168(k)(7) election—allowing them to opt out of bonus depreciation for qualified property placed in service during tax years 2023–2025—after the taxpayer’s external tax preparer inadvertently omitted the...
7701-4(d) of the Procedure and Administration Regulations, permitting its continued classification despite an extension to Date 7. 671-4(a), with the trustee reporting income on a separate statement rather than Form 1041.
9100-3 to an estate that missed a QTIP election under § 2056(b)(7), averting a potential $5M+ estate tax liability stemming from an incorrect Schedule M filing on Form 706.
9100-3, allowing them to elect entity classification treatment retroactive to their formation dates. The relief applies to elections that would have been effective on dates ranging from 2020 to 2025, with taxpayers required to attach a copy of the private letter ruling to their Form 8832 filings.
The IRS granted relief under § 1362(f) to an S corporation that inadvertently terminated its election after its operating agreements permitted disproportionate distributions, violating the one-class-of-stock requirement under § 1361(b)(1)(D).
9100-3, allowing a late election to self-certify as a Qualified Opportunity Fund (QOF) despite missing the original filing deadline. The IRS deemed the taxpayer’s Form 8996—filed with an administrative adjustment request (AAR) for Year 1—timely, validating the QOF election as of Date 2.
9100-3 to a taxpayer seeking to self-certify as a Qualified Opportunity Fund (QOF) for Year 1, despite a late election caused by Accounting Firm 1’s failure to file Form 8996 due to personnel turnover.
The IRS granted relief to a taxpayer whose late self-certification as a Qualified Opportunity Fund (QOF) risked forfeiting over $5 million in tax benefits due to an accounting firm’s oversight. 1400Z2(d)-1(a)(2)(i) to stand.
A limited liability company (LLC) narrowly avoided forfeiting millions in capital gains tax deferrals after the IRS granted relief for a missed Qualified Opportunity Fund (QOF) election deadline—an oversight attributed to its accounting firm’s internal turmoil.
The IRS has stepped in to prevent the unintended collapse of two S corporations’ tax status after trustees failed to file critical elections for trusts holding their stock, a misstep that could have triggered double taxation and the loss of pass-through benefits.
The IRS granted a foreign taxpayer an extension to file late Forms 8288-B for withholding certificates under Treas. Reg. 9100-3, which permits relief for missed regulatory elections when the taxpayer acted reasonably and in good faith. S.
9100-3. The decision highlights the IRS’s willingness to provide relief for late elections where timing issues stem from unforeseen events like a partner’s death. This ruling offers partnerships facing similar timing challenges a potential path to compliance, though it remains non-precedential.
9100-3 to a partnership (X) that missed its § 754 election deadline. The partnership may now file the election retroactively by attaching a written statement to an amended return or Administrative Adjustment Request (AAR).
6 million charitable deduction claimed by Piton Holdings LLC while upholding a 40% gross valuation misstatement penalty. The court’s ruling in Piton Holdings, LLC v. C. No.