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## Defining the Tax Court Reporter

The role of a tax editor requires a specific approach when analyzing Tax Court cases for the *Tax Court Reporter*. The core mission is threefold: presenting the critical *facts* of the case, explaining the *judicial power* exercised by the Tax Court, and highlighting any *novelty* or unusual aspects of the ruling. This is achieved through a structured narrative.

The narrative structure follows a strict pattern: Hook -> Facts -> Arguments -> Analysis -> Impact. The "Hook" immediately grabs the reader's attention with the central tax issue. The "Facts" section lays out the relevant details that led to the dispute. "Arguments" summarizes the positions of both the taxpayer and the IRS. "Analysis" distills the Tax Court's reasoning and legal basis for its decision. Finally, "Impact" explains the practical implications of the ruling for taxpayers and tax professionals.

A critical constraint is explaining relevant Internal Revenue Code sections in a clear and accessible manner. For instance, if a case hinges on Section 162, which allows deductions for ordinary business expenses, the editor must explain this deduction *before* discussing its application in the specific case. For example, consider *Zaheen v. Commissioner (T.C. Memo 2026-7)*. The case addressed equitable relief under Section 6015(f), which provides relief from tax liability for a spouse in certain circumstances when it would be inequitable to hold the requesting spouse liable. The Tax Court uses a multi-factor test outlined in Revenue Procedure 2013-34 to determine eligibility. Abuse and financial control serve as critical factors in the court's determination. "Abuse," includes physical, psychological, sexual, or emotional harm. "Financial control" occurs when the non-requesting spouse restricts access to financial records. In *Zaheen v. Commissioner (T.C. Memo 2026-7)*, the court decided on January 26, 2026, that Dr. Asia Zaheen, a physician, was entitled to innocent spouse relief from a tax deficiency arising from a 401(k) withdrawal controlled by her husband. The court emphasized that spousal abuse and financial control can negate the "reason to know" standard, strictly applying Revenue Procedure 2013-34. That procedure states that a requesting spouse's knowledge of a transaction can be superseded by a pattern of domestic abuse and deception. Recent cases, like *Salvi v. Commissioner* (2025), have further clarified that evidence of financial control, even if the requesting spouse was aware of the income-producing activity, can overcome the "reason to know" hurdle. Other relevant cases include *Robinson v. Commissioner (T.C. Memo 2020-134)*, which established that a non-requesting spouse's financial control can negate a requesting spouse's knowledge, even with general awareness of the income. The goal is to provide a comprehensive yet easily understandable account of the Tax Court's decisions and their implications, tailored for tax professionals and interested taxpayers alike.

## Structuring the IRS Bulletin Digest

The IRS Bulletin Digest section requires a dedicated persona, 'IRS_BULLETIN,' responsible for extracting and explaining critical information from the Internal Revenue Bulletin (IRB). The IRB is the IRS's official publication for rulings, procedures, and notices. Rulings published in the IRB are considered precedential, meaning taxpayers can rely on them unless revoked or modified. However, they do not have the same force of law as Treasury Regulations. The legal standing of Treasury Regulations has been impacted by the Supreme Court’s decision in *Loper Bright Enterprises v. Raimondo (2024)*, which overruled the *Chevron* doctrine. The *Chevron* doctrine previously required courts to defer to an agency's "reasonable" interpretation of an ambiguous statute. Now, under the Administrative Procedure Act (APA), courts must exercise independent judgment when interpreting statutes. This means the courts must now determine the "best" reading of the law, instead of automatically deferring to the IRS's interpretation. Post-*Loper Bright*, courts now apply the *Skidmore v. Swift & Co. (1944)* standard, where IRS guidance is given weight based on its thoroughness, consistency, and persuasive power, rather than automatic deference. Further, the *National Muffler Dealers Ass'n v. United States (1979)* standard, which evaluates a regulation's validity based on its contemporaneousness with the statute and consistency with prior IRS positions, is projected to revive in prominence.

The 'IRS_BULLETIN' persona must treat each distinct notice within the IRB as a separate "Deep Dive." For example, Notice 2026-3, which provides relief from additions to tax for underpayment of estimated tax related to new farmland deferral elections under the One Big Beautiful Bill Act (OBBBA), would be one deep dive. Another would be Notice 2026-5, which clarifies expanded Health Savings Account (HSA) availability following the July 2025 OBBBA amendments. These deep dives require dense, context-rich guidance. The One Big Beautiful Bill Act (OBBBA), officially designated as Public Law 119-21 and signed into law on July 4, 2025, made permanent the individual income tax rates established by the Tax Cuts and Jobs Act (TCJA) of 2017. It also increased the State and Local Tax (SALT) deduction cap to $40,000 for taxpayers earning under $500,000 and introduced new deductions for qualified tips and overtime wages. Each analysis must begin with an executive summary. This summary should succinctly capture the notice's core purpose, its impact on taxpayers, and any relevant deadlines or compliance requirements. The digest must then expand on this summary, providing a detailed explanation of the notice's provisions, relevant code sections, and examples to illustrate its application.

## Reporting on the Federal Register

The previous section addressed the importance of providing context-rich guidance when analyzing IRS notices, specifically regarding additions to tax for underpayment of estimated tax and Health Savings Account (HSA) availability following the July 2025 OBBBA amendments. These deep dives require dense, context-rich guidance. Each analysis must begin with an executive summary. This summary should succinctly capture the notice's core purpose, its impact on taxpayers, and any relevant deadlines or compliance requirements. The digest must then expand on this summary, providing a detailed explanation of the notice's provisions, relevant code sections, and examples to illustrate its application.

The *Federal Register* is another critical source of tax information, containing proposed and final Treasury Regulations that have the force of law. Reporting on these regulations requires a similar level of precision and clarity, but with a unique emphasis. The 'FEDERAL_REGISTER' persona instructions prioritize a structured approach, focusing on conciseness and practical application.

Context remains paramount. Any reporting on Treasury Regulations within the *Federal Register* must include sufficient background information to understand the regulation's purpose and scope. For example, when discussing regulations under Section 401(k), which governs qualified cash or deferred arrangements, we must briefly explain the overall purpose of 401(k) plans and the specific issues the regulations address. Given the Supreme Court’s decision in *Loper Bright Enterprises v. Raimondo (2024)*, the courts are no longer required to defer to an agency's "reasonable" interpretation of an ambiguous statute. Instead, they must exercise independent judgment to determine the "best reading" of the law. This means taxpayers now have a significantly lower bar to challenge Treasury Regulations that they believe exceed statutory authority. The IRS must now prove its interpretation is the *best* reading of the Code, not just a permissible one. The Tax Court applied this new standard in *Weston v. Commissioner* (2025), when it found that Treasury Regulation § 1.165-1(d)(3) was the "best interpretation" of Section 165(e) regarding casualty losses, rather than merely a permissible one. *Loper Bright* shifted the standard from *Chevron* deference to consideration under *Skidmore v. Swift & Co. (1944)*, where a regulation is weighed based on its thoroughness, consistency, and persuasive power.

For instance, in *3M Co. & Subsidiaries, Inc. v. Commissioner, 160 T.C. 50 (2023)*, the Tax Court originally relied on *Chevron* to uphold transfer pricing regulations under IRC § 482, which addresses the allocation of income and deductions among related entities. Following *Loper Bright*, such cases are being reconsidered on the basis of whether the regulation aligns with the "best" statutory interpretation.

A crucial aspect of reporting on regulations is highlighting the difference between the old rule and the new rule. This involves clearly articulating how the new regulation changes existing law or practice. For instance, if a regulation amends the definition of "compensation" for purposes of calculating 401(k) contributions, the reporting must explain the *previous* definition and how the *new* definition differs, including any specific examples of impacted employees or situations. The analysis should also reference Section 7805(b), which governs the retroactivity of rulings. Recent guidance emphasizes that taxpayer reliance on interim guidance, often issued as an IRS Notice or Revenue Procedure *before* formal regulations are published, is often subject to a "strict consistency requirement" across all eligible property or transactions for that year. This requirement means taxpayers cannot "cherry-pick" favorable parts of the interim guidance but must apply it in its entirety to all relevant transactions.

The "strict consistency requirement" prevents the IRS from applying rulings inconsistently among similarly situated taxpayers. This principle was affirmed in *International Business Machines (IBM) v. United States (1965)*, where the court held that the IRS abused its discretion by not providing "equal treatment" to similarly situated taxpayers; the IRS had provided a favorable ruling to one taxpayer, but not to IBM.

By adhering to these principles, we can effectively translate complex regulatory changes into actionable information for tax professionals and taxpayers alike.

## Translating Private Letter Rulings

Private Letter Rulings (PLRs) offer taxpayers insight into the IRS's stance on specific tax issues, although Section 6110(k)(3) of the Internal Revenue Code explicitly states that PLRs cannot be cited as precedent. Understanding their structure and limitations is crucial. Section 6110(k)(3) mandates that PLRs may not be used as precedent.

The analysis of a PLR should focus on extracting the core reasoning using a "Question -> Answer -> Cause -> Implications" framework. First, clearly identify the *question* the taxpayer presented to the IRS. Next, state the IRS's *answer* or conclusion. Crucially, the analysis must then delve into the *cause* – the specific statutes, regulations, and case law the IRS relied upon to reach its conclusion. Finally, discuss the *implications* of the ruling, keeping in mind its non-precedential nature.

Succinctness is paramount. While providing sufficient context for understanding is important, avoid unnecessary details or speculation beyond the scope of the ruling. For example, when summarizing a PLR concerning the deductibility of certain expenses under Section 162, which allows deductions for ordinary business expenses, the report should precisely state the type of expense, the IRS's rationale for allowing or disallowing the deduction, and the specific facts that influenced the determination. The analysis should not engage in broad discussions about Section 162 deductions in general. The IRS formalized a permanent Fast-Track Program for corporate PLRs in Rev. Proc. 2023-26, reducing the typical wait time to approximately 12 weeks, though it is generally not available if the request involves a closing agreement or is under examination/litigation. This Fast-Track program, replacing the pilot program (Rev. Proc. 2022-10), is restricted to issues primarily under the Associate Chief Counsel (Corporate), such as Section 355 spin-offs and Section 368 reorganizations. Taxpayers must request a pre-submission conference to discuss eligibility. Unlike traditional expedited PLR requests, the Fast-Track program generally does not require a demonstration of "business need" for the 12-week timeline, unless the taxpayer is requesting a ruling in *less* than 12 weeks.