Latest US Tax Court decisions and federal tax court opinions
The Internal Revenue Bulletin (IRB) 2026–21, published on May 18, 2026, delivers a significant regulatory adjustment that will resonate across the tax profession: the IRS has slashed the user fee for the Special Enrollment Examination (SEE) required to become an enrolled agent...
9100-3 to an estate that missed the deadline to elect portability of the deceased spouse’s unused estate tax exclusion (DSUE). 61 million per individual in 2024—thereby reducing future estate tax liability.
9100-3—which allows taxpayers to request discretionary relief for missed regulatory elections—for a parent company that failed to timely file a consolidated return election for its affiliated group.
9100-3 to a taxpayer who missed the 60-day deadline to file a § 336(e) election, allowing a stock sale to be treated as an asset sale for tax purposes. 336-1(b)(6).
The IRS has issued a non-precedential private letter ruling (PLR-112873-25) approving the use of indexed structured settlement annuities under § 130(c)(2)(A) of the Internal Revenue Code.
The Martins’ $332,500 charitable contribution deduction—a sum large enough to erase nearly a third of their 2018 tax liability—vanished in a single stroke when the Tax Court ruled their substantiation documents failed to include a single, mandatory sentence. The case, Martin v. C. Memo.
The stakes could not have been higher when the Martins claimed a $339,400 charitable deduction on their 2018 return—one of the most scrutinized figures in Tax Court history.
The Internal Revenue Service’s release of Rev. Proc. 2026-14 marks a seismic shift in the Opportunity Zones (QOZ) program, fundamentally altering the landscape for economically distressed communities seeking investment incentives.
7701-3. The relief allows the election to be effective as of the originally intended date, providing certainty for the taxpayer’s tax treatment. Taxpayers facing similar late-filing situations may seek analogous relief under the same provision.
The IRS granted relief to X Corporation, allowing its late S corporation election to be treated as timely filed under Section 1362(b)(5) of the Internal Revenue Code.
The IRS has revoked Private Letter Ruling 201949002, issued in 2019, which addressed whether accounting method changes could generate additional § 48 investment tax credits for qualifying energy property.
The IRS granted relief under § 1362(f) to an S corporation whose status inadvertently terminated after a trust failed to timely elect Electing Small Business Trust (ESBT) status under § 1361(e), causing the trust to become an ineligible shareholder.
9100-3 to an S corporation’s shareholders and purchaser, permitting a late §336(e) election after missing the original deadline tied to the target’s tax return due date.
A partnership’s failure to file a § 754 election—a critical tax mechanism that adjusts asset bases to reflect a partner’s death—could have triggered a $1M+ tax liability in unrealized gains. 9100-3, sparing the partnership from costly missteps.
The IRS granted a 45-day extension to a partnership to file its Form 3115 after its CPA inadvertently failed to upload the required application to the taxpayer’s timely filed federal income tax return.
The IRS granted permission for X to re-elect S corporation status effective Date 3—prior to the expiration of the five-year waiting period under Internal Revenue Code § 1362(g)—after C acquired 100% of X’s interests from A and B on that date.
The IRS granted a 120-day extension to a limited liability company (LLC) to file Form 8832, Entity Classification Election, after the taxpayer missed the 75-day retroactive window to elect corporate tax treatment. 7701-3.
A $5 million-plus estate faced imminent estate and generation-skipping transfer (GST) tax liabilities after an accountant erroneously filed Form 706, misclassifying QTIP property and triggering a failed QTIP election.
The IRS ruled in PLR-113278-25 that proposed modifications to an irrevocable trust executed prior to September 25, 1985, would not trigger a taxable event under the Generation-Skipping Transfer (GST) Tax, nor would they result in estate or gift tax implications for the grantor or beneficiaries.
The IRS issued Private Letter Ruling PLR-113277-25, confirming that modifications to an irrevocable trust established before September 25, 1985, will not jeopardize its GST tax-exempt status or trigger estate or gift tax consequences. The ruling addresses four key questions: 1. 2601-1(b)(4). 2.
The IRS has ruled that proposed modifications to a pre-September 25, 1985 irrevocable trust will not jeopardize its generation-skipping transfer (GST) tax-exempt status, provided the changes comply with regulatory safe harbors.
The IRS ruled that proposed modifications to an irrevocable trust created before September 25, 1985—with no post-1985 additions—would not jeopardize its generation-skipping transfer (GST) tax exempt status, trigger estate tax inclusion for the grantor, or create gift tax...
The IRS has issued a favorable private letter ruling (PLR-113274-25) affirming that proposed modifications to an irrevocable trust will not jeopardize its generation-skipping transfer (GST) tax exempt status.
The IRS ruled favorably in PLR-113273-25, granting four requested rulings regarding proposed modifications to an irrevocable trust created before September 25, 1985.
The IRS has issued a rare lifeline to an S corporation whose election was inadvertently terminated after trust shareholders failed to make required Qualified Subchapter S Trust (QSST) or Electing Small Business Trust (ESBT) elections.
The IRS granted relief under Section 1362(f) to an S corporation whose election terminated when a trust failed to timely elect Electing Small Business Trust (ESBT) status, concluding the termination was inadvertent.
1 million tax bill from the IRS—one that threatened to upend his life and business. At the heart of the dispute was a $2 million offer-in-compromise (OIC) Joseph submitted to settle his tax liabilities for 2011 through 2017, along with a $100,000 installment agreement (IA) request.
The Tax Court just handed the IRS a $30 million victory—and a warning shot to promoters of syndicated conservation easements.
S. Tax Court issued its ruling in Kimberly Road Fulton 25, LLC v. Commissioner and South Fulton Parkway 58, LLC v. Commissioner on May 4, 2026. 5% of what the taxpayers sought. The IRS had argued for total disallowance, while the partnerships claimed the full $30 million was justified.
The Tax Court has delivered a stark warning to taxpayers peddling microcaptive insurance schemes, sustaining $454,472 in 40% accuracy-related penalties under § 6662(i) for tax years 2012–2015. The decision in Kadau v. C. Memo.
The IRS proposed sweeping changes to information reporting thresholds under § 6041 and § 6041A, which govern payments made in the course of a trade or business.
A multinational taxpayer successfully persuaded the IRS Chief Counsel to retroactively alter its cost allocation method for controlled services transactions under the Comparable Profits Method (CPM), a change approved as a valid setoff under Treas. Reg. 482-1(g)(4).
S. investments from taxation when earned by foreign governments. The ruling addressed the Institution’s request to confirm that its accident insurance operations, medical clinic management, and workplace safety guidance did not constitute commercial activities under Section 892. S.
The IRS granted a taxpayer’s request to partially revoke a net capital gain election under Section 163(d)(4)(B), which permits taxpayers to include net capital gain in investment income for purposes of calculating deductible investment interest expense.
9100-3 to a taxpayer seeking to file a late §336(e) election, allowing the deemed asset sale treatment for a stock disposition of an S corporation. The relief hinged on the taxpayer’s demonstration of reasonable action and good faith, with no prejudice to the government.
The IRS granted a 45-day extension to a corporation and its subsidiaries after a CPA inadvertently failed to upload two original Forms 3115 to the taxpayer’s timely filed consolidated federal income tax return.
The IRS has issued a private letter ruling (PLR-114550-25) confirming that an estate may deduct income distributions to charitable organizations under Section 642(c)(1) of the Internal Revenue Code, provided the distributed amounts are includible in the estate’s gross income.
The IRS concluded in a recent private letter ruling (PLR-112870-25) that periodic payments under an indexed structured settlement annuity contract qualify as "fixed and determinable" under § 130(c)(2)(A) and that the annuity qualifies as a "qualified funding asset" under §...
The IRS granted relief under § 1362(f) to an S corporation whose status terminated after trusts holding its shares failed to make timely Qualified Subchapter S Trust (QSST) elections under § 1361(d).
2642-7 to a taxpayer seeking to retroactively allocate Generation-Skipping Transfer (GST) exemption to transfers made in Year 1. The relief permits the taxpayer to file a supplemental Form 709 to correct the omission, avoiding potential GST tax liability on future distributions to skip persons.
The IRS granted a 60-day extension under Treas. Reg. 9100-3 to a real estate partnership for a late § 163(j)(7)(B) election, allowing it to opt out of the 30% business interest deduction limitation for its Year 2 taxable year.
A taxpayer narrowly avoided a multimillion-dollar tax liability when the IRS granted a 60-day extension to file a late election to treat its business as a real property trade or business (RPTOB).
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.