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.
9100-3 to a taxpayer seeking to file a late § 168(h)(6)(F)(ii) election, allowing it to avoid unintended tax-exempt controlled entity status.
9100-3 to X, a State LLC taxed as a partnership, allowing it to file a late § 754 election for its taxable year ended Date 1.
A taxpayer nearly lost Qualified Opportunity Fund (QOF) status—and the potential tax deferrals that come with it—after a trusted tax professional overlooked a critical filing deadline.
The IRS granted rare relief to a taxpayer who missed the deadline to self-certify as a Qualified Opportunity Fund (QOF), preserving over $5 million in potential tax benefits after a tax professional failed to file Form 8996.
9100-3 of the Procedure and Administration Regulations, allowing an LLC to retroactively elect corporate tax treatment via Form 8832 effective Date 2. 7701-3. This ruling permits the LLC to avoid unintended tax consequences by validating its corporate election retroactively.
The Internal Revenue Bulletin No. 2026–27 delivered a pivotal update to the Inflation Reduction Act’s energy community bonus credits, reshaping the financial landscape for renewable energy developers.
In Frederick Whigham v. C. Memo. 18 in unpaid federal income taxes for tax years 2011, 2014, 2015, and 2017.
S. Tax Court delivered a landmark ruling in Hee v. N. Hee and his closely held corporation, Waimana Enterprises, Inc.
The stakes in Charlton C. Tooke III v. 8 million in unpaid federal taxes spanning tax years 2012 through 2017. At issue is whether the IRS abused its discretion in rejecting Tooke’s Offer-in-Compromise (OIC) and sustaining a Notice of Federal Tax Lien (NFTL) and proposed levy actions.
The Internal Revenue Bulletin No. 2026–26, released on June 22, 2026, introduces three pivotal developments reshaping tax administration and compliance across estate planning, nonprofit governance, and renewable energy incentives.
The IRS has ruled that for purposes of computing accuracy-related penalties under IRC § 6662, a partnership is treated as an individual subject to tax for the reviewed year.
The IRS has ruled that items of income omitted from a return but adequately disclosed under IRC § 6501(e)(1)(B)(iii) are excluded from both the numerator and denominator when calculating the 25% omission threshold under IRC § 6501(e)(1).
C. § 574, which governs confidentiality in federal alternative dispute resolution (ADR) processes.
The IRS granted a 90-day extension to a taxpayer seeking to retroactively elect Interest Charge Domestic International Sales Corporation (IC-DISC) status under § 992 of the Internal Revenue Code, despite the taxpayer’s initial filing of an invalid Form 4876-A.
9100-3 of the Procedure and Administration Regulations to an estate that missed its portability election under Section 2010(c)(5)(A) of the Internal Revenue Code.
The IRS granted relief under § 1362(f) to an S corporation whose election terminated after failing to file an Electing Small Business Trust (ESBT) election under § 1361(e)(3).
7701-3, to be treated as a corporation for federal tax purposes. The taxpayer had intended to elect corporate status effective on a specified date but missed the filing deadline due to an administrative oversight. 9100-3 when taxpayers demonstrate good faith and no prejudice to the government.
A single checkbox on a taxpayer’s Form 709 nearly cost her over $5 million in lost Generation-Skipping Transfer (GST) tax exemption—but the IRS stepped in with a lifeline.
9100-3 of the Procedure and Administration Regulations. The elections were deemed effective as of Date 2, with the taxpayer receiving 120 days from the date of the PLR to file the required forms. This relief is non-precedential and applies solely to the facts presented in the ruling.
9100-3 to an estate seeking a retroactive Qualified Terminable Interest Property (QTIP) election under § 2056(b)(7), allowing the marital deduction despite a missed filing deadline.
S. S. tax purposes. S. trade or business—also prompted the IRS to decline ruling on the bank’s wholesale liabilities, instead opting for a closing agreement. S. operations, where missteps in liability allocation or recordkeeping can trigger costly audits or disallowed deductions.
The IRS has granted two non-precedential rulings (PLR-115162-25) that clarify self-dealing rules under Section 4941 for private foundations.
The IRS has ruled affirmatively in a private letter ruling (PLR-115161-25) that the estate administration exception under Treas. Reg. 4941(d)-1(b)(3) may apply to transactions involving Company Stock held in Revocable Trusts for a private foundation.
The IRS has approved two critical exceptions under § 4941 permitting transactions involving Company Stock held in revocable trusts, provided strict conditions are met.
The IRS has approved exceptions to the strict self-dealing rules under Section 4941 for transactions involving a private foundation, revocable trusts, and a closely held corporation, provided specific conditions are met.
The IRS has issued guidance clarifying when the estate administration exception under Treas. Reg. 4941(d)-1(b)(3) applies to transactions involving private foundations, revocable trusts, and estate assets.
The IRS ruled that a proposed cross-border redomiciliation qualifies as a tax-free reorganization under § 368(a)(1)(F), a provision allowing corporations to restructure without triggering gain or loss recognition. S.
The IRS granted a 120-day extension under § 2642(g) to a taxpayer who failed to allocate GST exemption to a trust transfer, retroactively effective to the original funding date.