Latest US Tax Court decisions and federal tax court opinions
9100-3 to a foreign entity that missed the deadline to file Form 8832, allowing it to elect partnership classification effective Date 2. 7701-3 to be classified as a partnership for federal tax purposes.
S. and foreign-source income, particularly for income subject to Section 951A (GILTI) and deduction eligible income (DEI) under Section 250.
The United States Tax Court has delivered a landmark ruling in Sitaraman Jagannath v. C. Memo. 2026-92 (Sept. 50 in additions to tax for failing to file required forms.
S. Tax Court just handed down a stark reminder to taxpayers: forgetting to report IRA distributions can cost you $80,292 in back taxes, penalties, and interest. In Pal v. C. Memo.
The stakes in Swain v. 98 in unpaid federal income taxes for tax years 2017–2019, a balance that ballooned with penalties and interest after the Swains filed late returns. S.
The Tax Court’s September 24, 2026, decision in Valarie Lindsey v. C. Memo. 2026-94) delivered a stark reminder to taxpayers: the 90-day window to challenge an IRS deficiency notice is not a suggestion.
The stakes couldn’t have been higher for Brenton E. Williams and Octavia P. Williams, a military family whose home in Panama City, Florida, was reduced to splinters when Hurricane Michael made landfall as a Category 5 storm on October 10, 2018.
The stakes could not be higher in Toscano Holdings, LLC v. 7 million valuation by the IRS, with the Tax Court now poised to determine whether the agency’s denial of Appeals rights was lawful.
7 million tax deficiency and a misplaced Final Partnership Adjustment (FPA). In Kings Road Property, LLC v. C. No. 11 (Sept.
S. taxpayers permission to make a retroactive Qualified Electing Fund (QEF) election for their investment in a Passive Foreign Investment Company (PFIC), avoiding severe tax penalties under the default PFIC regime.
9100-3 of the Procedure and Administration Regulations. The rulings permit the taxpayer to retroactively elect S corporation status for X, Y, and Z, effective as of their respective formation dates, despite the late filing of Form 2553.
D. 163-16) authorizing a $10,000 annual deduction for qualified passenger vehicle loan interest (QPVLI) but restricting eligibility to vehicles that undergo final assembly in the United States.
S. Tax Court issued a Memorandum Opinion sustaining deficiencies and fraud penalties totaling $780,251 against tax preparer Dawn C. Cottman for tax years 2009–2011.
S. taxable income by more than $100 million through an aggressive transfer pricing scheme. The potential award—up to 30 percent of the collected proceeds under Internal Revenue Code § 7623(b)(1)—would have been one of the largest in IRS history. S.
The Tax Court’s September 16, 2026 ruling in Christopher Aubuchon v. C. Memo. 2026-87) delivers a stark warning to tax protesters: $57,608 in total liabilities for a Stanford-educated entrepreneur who insisted his wages and business income were not taxable.
35 million in penalties—while simultaneously asserting its authority to police the agency’s compliance with statutory notice requirements. In Philips G. Groves v. C. Memo. 2026-86 (filed Sept.
The stakes couldn’t have been higher when the IRS filed a $730,027 federal tax lien against Justin Joseph Moore in 2025, threatening to derail his commercial real estate business just as it teetered on the brink of recovery.
The U.S. Tax Court has handed down a $323,924,795 tax deficiency ruling against Sysco Corporation, the nation’s largest foodservice distributor, in a dispute over whether the company could claim $324 million in dividends-received deductions under Section 245A for foreign...
The IRS ruled in a non-precedential memorandum that return information of taxpayers not identified by a whistleblower may be disclosed during non-docketed administrative proceedings if the disclosure arises from determining civil or criminal liability and does not impair investigations.
The IRS granted a 60-day extension to two taxpayers who missed the deadline to elect under § 266 to capitalize carrying costs, according to a private letter ruling (PLR) issued on an unspecified date in 2026.
The IRS has approved a judicial reformation of an irrevocable trust to correct a scrivener’s error and align the trust’s terms with the settlors’ original intent to include a stepchild and their descendants as beneficiaries.
The IRS granted relief under § 1362(f) to an S corporation whose election terminated after a trust failed to file a required Electing Small Business Trust (ESBT) election under § 1361(e), saving the company from potential tax liabilities and compliance adjustments.
9100-3 to an LLC that missed the deadline to file Form 8832, the election to be treated as a corporation for federal tax purposes. The taxpayer had intended to elect corporate classification but failed to file the form on time.
9100-3, the regulation governing extensions for regulatory elections. 7701-3(c), which governs entity classification elections.
The IRS granted relief under § 1362(f)—which allows the IRS to waive disqualifications for inadvertent S corporation election errors—for a corporation that failed to obtain a required shareholder consent and missed an ESBT election, both of which would have otherwise terminated its S status.
The IRS granted a 120-day extension to a limited liability company treated as a partnership to retroactively file a late § 754 election, resolving an inadvertent filing oversight that could have triggered significant tax inefficiencies for the entity and its partners. 9100-3.
The September 14, 2026 edition of the Internal Revenue Bulletin (IRB No.
The stakes could not have been higher for David T. Tunkl, a high-flying art dealer whose tax troubles now serve as a cautionary tale for S corporation shareholders and art dealers alike.
The stakes could not be higher. C. § 7623(b)—after alleging that his 2017 interview with the IRS provided the legal foundation for the agency’s multibillion-dollar crackdown on abusive tax shelters.
The stakes could not have been higher for Katanga Properties, LLC. 2 million charitable contribution deduction claimed on the partnership’s 2020 tax return—a deduction that, if sustained, would have slashed the partnership’s tax liability by over $400,000 in federal taxes alone.