news• US Tax Court
Kolar v. Commissioner
The $290,000 Hobby Loss Challenge At stake was over $292,000 in tax deficiencies, plus substantial penalties, as the IRS challenged Kenward Kolar's deductio
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Latest US Tax Court decisions and federal tax court opinions
The $290,000 Hobby Loss Challenge At stake was over $292,000 in tax deficiencies, plus substantial penalties, as the IRS challenged Kenward Kolar's deductio
The $11,000 Surprise After the Deal Was Signed Ingrid Maria Persson believed she had resolved her 2019 tax obligations after entering into an Installment Ag
Judge Holmes Reprimands Lawyer for AI 'Hallucinations' in $2.2M Case The Tax Court recently addressed a $2.2 million tax deficiency case involving a now-dec
Foundation Cleared for 'Socioeconomic Mobility' Grants A private foundation focused on promoting socioeconomic mobility has received IRS approval for its sc
IRS Greenlights Pension Plan Assumption Tweaks The IRS has approved a taxpayer's request to modify retirement rate assumptions for their defined benefit pen
Foundation Secures Approval for Dual Grant Program In a recent victory for private foundations, the IRS has given its stamp of approval to a foundation seek
Executive Writes Off Porn App & Tent Living Costs A high-income tech executive, earning approximately $350,000 annually, successfully challenged the IRS, ma
$48 Million Easement Case Hits Penalty Roadblock At stake is a staggering $48.1 million charitable contribution deduction tied to a conservation easement do
The Remand Reversal A Russian scientist who originally won his Tax Court case, claiming his lab salary was a tax-exempt 'grant', has now lost on remand. The
Treasury Targets Waste and Fraud with New Data System The Treasury Department is formalizing its oversight of financial assistance programs with a new syste
IRS Proposals Shift Fuel Incentives from Blending to Production The IRS has issued proposed regulations for the Section 45Z Clean Fuel Production Credit, ma
Late Petition Saved by IRS Waiver, But Penalties Stick Ordinarily, missing the 30-day deadline to petition the Tax Court is a fatal error, depriving the cou
Which Came First: The Research or the Credit Study? Forget the age-old question of the chicken or the egg; in this case, the Tax Court grappled with which c
Which Came First: The Research or the Credit? The Tax Court faced a 'chicken or the egg' dilemma in George v. Commissioner—did the research create the cre
Partners' Last-Minute Bid to Block Settlement Fails In a dispute over a $48.9 million conservation easement deduction, the Tax Court has denied a motion by
Bulletin 2026-6: Bonus Depreciation Expanded & Rollover Notices Updated This edition of the Internal Revenue Bulletin (IRB) contains updates spanning income
Regulators Ease Bank Stress Tests; IRS Eyes Benefit Plans In a register reflecting both regulatory easing and continued compliance oversight, the Office of
Administrative Watch: IRS Reviews Compliance Burdens The IRS and Treasury are soliciting public feedback on information collections related to employee bene
Tax Pro With 3,000 Clients Audited Over 'Donation Box' Income A tax preparer who filed over 3,000 returns for others now faces a tax bill of roughly $43,000
The $38 Million FASIT Flop Aventis, a subsidiary of Sanofi, is facing a hefty tax bill of approximately $38 million after the Tax Court disallowed its use of
IRS Reviews Compliance Burden for Dividends and Contracts The IRS is soliciting public input on the compliance burden associated with dividend reporting and
IRS Opens Comment Period on Tax Compliance Forms The IRS is seeking public comment on the information collection requirements associated with two distinct t
IRS Opens Comment Period on Tax Forms ...The IRS has published three notices in the Federal Register seeking public comment on information collection activi
Billboard Income Cleared as Real Estate Rent In a victory for real estate investment trusts (REITs) involved in outdoor advertising, the IRS has ruled priva
IRS Salvages IC-DISC Election Despite Missing Signatures The IRS has granted a taxpayer a 90-day extension to file a corrected Form 4876-A, salvaging their
IRS Grants Relief for Incomplete IC-DISC Election In a recent private letter ruling, the IRS granted an extension to a taxpayer to perfect its election to b
IRS Approves Billboard Rents as Qualifying REIT Income In a recent private letter ruling (PLR-113200-22), the IRS has ruled that income derived from outdoor
S Corp Target Salvages Asset Sale Treatment The IRS has granted an S Corporation target and its shareholders a 75-day extension to file a Section 336(e) ele
Deductive Value Method Escapes Section 1059A Basis Cap A U.S. importer has won a significant victory, securing a favorable private letter ruling from the IR
Foreign Entity Granted 120-Day Grace Period for Partnership Status The IRS granted a foreign entity a 120-day extension to file Form 8832, "Entity Classific
Estate Granted Extension to Salvage Portability Election In a move offering relief to a tardy estate, the IRS has granted a 120-day extension to file Form 7
Late Election Allowed for Partnership Blindsided by State Tax Rules The IRS granted a partnership a 60-day extension to elect out of Section 168(k) bonus
Partnership Ownership Voids S Election An attempted S Corporation election by an entity (X) with an ineligible shareholder – specifically, a multi-member LL
IRS Grants Foreign Entity Time to Fix Partnership Election The IRS has granted a foreign entity, referred to as "Company," a 120-day extension to file Form
IRS Blesses Multi-Tiered Cross-Border Split and Share Retention A foreign parent company (Distributing 3) secured IRS approval for a complex, multi-step sep
Timing Glitch Threatens Post-Reorg QSub Status The IRS recently granted relief to an S Corporation that inadvertently jeopardized its subsidiary's Qualified
LLC Wins Extension After Inadvertent Filing Error In a recent private letter ruling, the IRS granted Taxpayer X, a limited liability company treated as a pa
Foreign Entity Wins Extension for Disregarded Status In a recent ruling offering a lifeline to businesses navigating complex tax elections, the IRS granted
IRS Grants Relief for Missed Basis Adjustment Election In a recent private letter ruling (PLR), the IRS granted Partnership X a 120-day extension to file an
County Support Org Wins Section 115 Exclusion The IRS has ruled that a nonprofit corporation created to improve the efficiency of a county government can ex
Sales Manager Dimmed on $250k Energy Deduction Scheme A lighting sales manager's aggressive attempt to eliminate his tax liability using purchased energy ef
Vendor Advance or Windfall? A $2.3 Million Surprise Crawford Pile Driving, LLC sought to settle approximately $56,000 in federal unemployment (FUTA) and emp
From Loss to Windfall: $850k Profit Sinks Contractor's Offer A Michigan construction company, Crawford Pile Driving, LLC, found its attempt to settle unpaid
The $28,000 Deduction: When Legal Fees Become Personal Losses Joanne G. Rosso found herself in Tax Court contesting a $5,388 deficiency, the result of deduc
Tax Court: Economic Substance 'Relevancy' Test Survives Codification In a closely watched case with significant implications for microcaptive insurance arra
Tax Court Unleashes 40% Penalty in First Test of Codified Economic Substance 'Relevancy' In a precedential 'Reviewed' opinion, the Tax Court not only invali
Tax Court: Economic Substance Doctrine Requires 'Relevancy' Test The Tax Court, in a reviewed opinion with far-reaching implications, has sharpened the teet
The $45,000 Substantiation Struggle At the heart of this Tax Court case lies a $45,000 deficiency assessed by the IRS against John Doe, a self-employed cons
Medical Hardship No Excuse for 'Radio Silence' in $186k Levy Case A taxpayer facing a levy for $186,182 in unpaid taxes from 2015-2019 found no refuge in hi
Documentation Gap Sinks EITC Claim for Disabled Sister The Tax Court dashed the Graham family's hopes for a $3,686 Earned Income Tax Credit (EITC) in 2022,