The IRS has clarified that small corporations failing to file Form 5472 or maintain records under Section 6038A may qualify for "liberal" application of reasonable cause relief, potentially avoiding a $25,000 penalty per violation.
S. tax purposes. The taxpayer’s election statement, prepared by qualified tax professionals, was never acknowledged by the IRS despite being filed in accordance with procedural rules.
9100-3 to a taxpayer who missed the deadline for making a § 168(k)(7) election to opt out of bonus depreciation. The taxpayer’s request stemmed from a preparer’s oversight—specifically, the failure to attach the required election statement to the original return.
9100-3 to a taxpayer who missed the deadline to file Form 8996, the self-certification election for a Qualified Opportunity Fund (QOF).
9100-3 to a taxpayer that missed the deadline to file Form 8996, the self-certification election for Qualified Opportunity Funds (QOFs). The taxpayer sought relief after failing to timely file the form due to reasonable reliance on a tax advisor, demonstrating that it acted in good faith.
The IRS has granted relief under Section 1362(f) to a taxpayer whose S corporation election terminated after a trust failed to file a required Qualified Subchapter S Trust (QSST) election, potentially exposing the corporation to retroactive tax liability.
The IRS granted § 1362(f) inadvertent termination relief to X, an S corporation, after Trust 2 failed to make a QSST election (§ 1361(d)) upon acquiring X stock.
" The omission, attributed to the tax preparer’s oversight, risked requiring the taxpayer to use the Alternative Depreciation System (ADS) for its partnership assets, potentially resulting in significant lost depreciation deductions. 9100-3 to correct the error.
The IRS granted a 120-day extension to an LLC that missed the deadline to file Form 8832, the entity classification election, due to an inadvertent failure to submit the form. 9100-3, which permits extensions for regulatory elections when the taxpayer acts reasonably and in good faith.
9100-3—which provides relief for late regulatory elections—to two entities (X and Y) to file Form 8832 for entity classification elections. The IRS approved a 120-day extension for both entities to elect partnership and disregarded entity status, respectively, effective Date 2.
The IRS ruled in a non-precedential Private Letter Ruling (PLR) dated April 2026 that a regulated public utility’s assets do not qualify as public utility property under § 168(i)(9), which defines property used by utilities subject to normalization rules.
The IRS ruled that bonds financing a state-formed political subdivision’s advanced water purification project would not meet the private business use tests under § 141(b), resolving concerns that contracts with privately owned water utilities might jeopardize tax-exempt status.
The Tax Court’s April 22 ruling in Cathryn A. Simmons v. Commissioner delivered a harsh lesson in the unforgiving nature of tax substantiation rules, costing a boutique owner and landlord $80,536 in additional tax for 2017, a $16,107 accuracy-related penalty, and $4,219 for 2019.
In Marie Kanda v. C. Memo. 2026-XX), the Tax Court addressed whether Marie M. Kanda, who filed pro se, qualified for COVID-19-related credits after the IRS issued a $26,560 deficiency notice for tax year 2022.
9100-3 to an estate that missed the portability election deadline under § 2010(c)(5)(A), allowing the surviving spouse to claim the deceased spousal unused exclusion (DSUE) amount.
The IRS ruled that a proposed spin-off and merger qualified as tax-free under Section 355—which governs tax-free corporate spin-offs—and Section 368—which defines tax-free reorganizations—according to a private letter ruling issued in April 2026.
9100-3 of the Procedure and Administration Regulations. The taxpayers had missed the filing deadline for their intended corporate elections but demonstrated they acted in good faith and that granting relief would not prejudice the government’s interests.
The IRS granted a 75-day extension to an S corporation that missed the deadline to file a § 336(e) election for a $X million stock sale, treating the transaction as an asset sale for tax purposes.
The IRS granted § 9100-1 relief to a taxpayer who requested an extension of time to file Form 8996—the self-certification form for Qualified Opportunity Funds (QOFs)—after missing the deadline.
The IRS has issued two critical notices—Notice 2026-24 and Notice 2026-25—that collectively address penalty relief for qualifying farmers and fishermen while also adjusting housing expense limitations for 2026 under § 911.
The Tax Court’s April 16 ruling in Sawyer v. Commissioner confirmed that Jonathan Sawyer constructively received $160,900 in taxable income when his Northwestern Mutual life insurance policy terminated in 2015, despite receiving no cash.
The Tax Court’s decision in Kelby Daniel Reyes Barrios v. Commissioner serves as a warning to gig workers and freelancers: even $15,206 in unreported income can result in a $3,842 tax deficiency, plus penalties and interest.
The Internal Revenue Service’s proposed 1% excise tax on remittance transfers under Section 4475 of the Internal Revenue Code marks a significant expansion of federal tax authority into the cross-border payments sector.
The IRS has finalized a landmark deduction under the One, Big, Beautiful Bill Act (OBBBA), allowing taxpayers to claim up to $25,000 annually for qualified tips—a provision that reshapes how tipped workers and their employers navigate the tax code.
The Internal Revenue Service issued its 27th annual report on the Advance Pricing and Mutual Agreement (APMA) Program, providing critical insights into transfer pricing enforcement trends for 2025. Announcement 2026-8, released in Bulletin No.
The Tax Court’s April 8 ruling in Varian Med. , Inc. & Subs. v. 3 million foreign tax credit disallowance—highlighting the high-stakes transition from the old worldwide tax system to the TCJA’s territorial regime.
S. Tax Court. Pratt’s $10,000 dispute wasn’t just about the money; it was a jurisdictional showdown testing whether the Tax Court could assert authority over the IRS when no administrative or judicial action had been taken against the target taxpayer. C. Circuit’s recent decision in Kennedy v.
The IRS Bulletin No. 2026-15 arrives amid a period of heightened regulatory flux, where long-standing provisions intersect with evolving legislative priorities and emerging economic realities.
48-4 election for qualified rehabilitation expenditures (QREs). The taxpayer’s accounting firm inadvertently failed to file the election with the original tax return, prompting the request for relief.
9100-3 to a partnership that missed a timely § 754 election after a partner’s death, ruling the failure was inadvertent and not prejudicial to the government.