Latest US Tax Court decisions and federal tax court opinions
The IRS Bulletin No. 2026-15 arrives amid a period of heightened regulatory flux, where long-standing provisions intersect with evolving legislative priorities and emerging economic realities.
48-4 election for qualified rehabilitation expenditures (QREs). The taxpayer’s accounting firm inadvertently failed to file the election with the original tax return, prompting the request for relief.
9100-3 to a partnership that missed a timely § 754 election after a partner’s death, ruling the failure was inadvertent and not prejudicial to the government.
A taxpayer’s $A in deferred capital gains hung in the balance when an overlooked regulatory deadline threatened to disqualify their Qualified Opportunity Fund (QOF) election. 9100-3, which allows extensions for regulatory elections when taxpayers act reasonably and in good faith.
The IRS granted an LLC’s request for both an extension to file a late S corporation election and entity classification relief after the company inadvertently failed to submit Form 2553 on time.
The IRS granted a taxpayer’s request for an extension to make a late § 168(h)(6)(F)(ii) election, allowing the taxpayer to avoid tax-exempt entity status for depreciation purposes.
The IRS granted a taxpayer’s request for regulatory relief after a tax advisor’s oversight led to a missed deadline for electing Qualified Opportunity Fund (QOF) status, saving the taxpayer from a potential $A loss.
The IRS granted a 120-day extension under Treas. Reg. 9100-3 to X, a state LLC taxed as a partnership, to file a late § 754 election for its taxable year ended Date 1.
The IRS granted a 120-day extension to a partnership that missed its § 754 election deadline, ruling the taxpayer acted reasonably and in good faith.
9100-3 for a taxpayer and transferee to make a late §362(e)(2)(C) election after failing to comply with regulatory deadlines.
The IRS granted a 75-day extension to a taxpayer and transferee for entering into a binding agreement and filing an election statement under Section 362(e)(2)(C), which governs basis adjustments in tax-free corporate formations.
The IRS has granted a 75-day extension to a taxpayer seeking to file a late closing-of-the-books election under Section 382, allowing the corporation to offset post-change taxable income with pre-change losses.
1502-75(a)(1) of the Income Tax Regulations, permitting the affiliated group to designate the parent corporation as the common parent for the taxable year ending Date 1. 9100-3 of the Procedure and Administration Regulations.
Taxpayers recently secured a 120-day extension under Section 2642(g) of the Internal Revenue Code to retroactively elect out of the automatic allocation of their Generation-Skipping Transfer (GST) exemption under Section 2632(c)(5).
The IRS granted relief to a state limited liability company (LLC) that inadvertently missed deadlines for both an entity classification election and an S corporation election.
In a rare and narrowly tailored decision, the IRS granted a private letter ruling (PLR-114045-25) allowing a taxpayer to retroactively elect under §336(e) to treat a stock sale as an asset sale, despite missing the regulatory deadline.
A domestic limited liability company (LLC) narrowly avoided default classification as a disregarded entity after the IRS granted a 120-day extension to file Form 8832, Entity Classification Election. 7701-3 but missed the filing deadline, risking retroactive tax liabilities and compliance penalties.
S. domestic corporations for federal tax purposes—and the agency granted consent, effective January 1, 2025. S. taxation under the election.
An estate recently secured a 120-day extension to make a QTIP election under § 2056(b)(7) after an accounting firm’s error nearly cost it a critical marital deduction. 9100-3, which allows extensions for regulatory elections when taxpayers act reasonably and in good faith.
The IRS granted a 120-day extension under Treas. Reg. 9100-3 for a taxpayer’s late Qualified Subchapter S Subsidiary (QSub) election under § 1361(b)(3), after determining the failure resulted from an inadvertent error with no tax avoidance motive.
9100-3 to a foreign entity seeking to file Form 8832 to elect corporate classification, resolving a late classification election request. 9100-3, which permits extensions when reasonable cause is demonstrated.
The IRS granted relief to a taxpayer seeking to file a late S corporation election under Section 1362(b)(5) of the Internal Revenue Code, allowing the election to be treated as timely if the taxpayer submits a completed Form 2553 within 120 days of this letter and includes a...
The IRS granted a 120-day extension to an LLC that missed the deadline to file Form 8832, the Entity Classification Election, after revoking its S corporation status.
The IRS granted a 120-day extension to a taxpayer who failed to elect out of the automatic Generation-Skipping Transfer (GST) exemption allocation for transfers totaling millions of dollars to three irrevocable trusts.
The IRS has ruled that a charitable lead annuity trust (CLAT) may accelerate all remaining annuity payments to a donor-advised fund (DAF) and terminate early without triggering penalties under Section 4941 (self-dealing), Section 4945 (taxable expenditures), or Section 507 (termination taxes).
The IRS granted relief under Section 1362(f) to an S corporation whose status terminated after a trust failed to file a required Qualified Subchapter S Trust (QSST) election on time, potentially exposing the company to millions in double taxation.
The IRS ruled that rental income received by an S corporation was not passive investment income under § 1362(d)(3)(C)(i), concluding that the corporation’s active involvement in managing and operating its rental properties disqualified the income from passive classification.
In a non-precedential private letter ruling (PLR-103329-21), the IRS has confirmed that a rural telephone cooperative may exclude from gross income the portion of gain allocable to patrons' use of its network when properly allocated.
S. Tax Court issued its final ruling in Daniel Isaiah Thody v. Commissioner—a case that exposed a brazen tax evasion scheme netting the IRS over $160,000 in unpaid taxes and fraud penalties across five years.
The U.S. Tax Court on Monday dealt a $5 million-plus blow to Professional Employer Organizations (PEOs) nationwide, ruling that only common law employers—not statutory employers or §3504 agents—qualify for lucrative federal tax credits like the Work Opportunity Tax Credit (WOTC)...
Thermal Circuits Inc. 3 million in tax deficiencies and penalties. 3 million from BAT’s subsidiary to expand its Salem, Massachusetts manufacturing facility. 28 million deficiency for 2017 alone, plus $255,429 in accuracy-related penalties.
The IRS on Friday unveiled proposed regulations that would overhaul longstanding arbitrage rules governing tax-exempt bonds, introducing sweeping changes to compliance mechanisms under Section 148 and Section 150 of the Internal Revenue Code.
S. tax liability by treating gains from the sale of foreign stock as foreign-source income. The relief, issued under Treas. Reg. 9100-3, hinged on the taxpayers’ reasonable reliance on tax professionals who failed to advise them of the election’s availability.
The IRS ruled that a county-created nonprofit’s income from blighted property reclamation qualifies for exclusion under § 115(1) of the Internal Revenue Code, which exempts income derived from essential governmental functions accruing to a political subdivision.
The IRS has ruled that a rural telephone cooperative may exclude from its consolidated gross income the portion of gain from the sale of a partnership interest that is allocable to patrons’ prior use of the partnership’s network.
A tribal-owned corporation petitioned the IRS for certainty on a proposed restructuring under the Oklahoma Indian Welfare Act (OIWA), seeking to avoid a potential multimillion-dollar tax liability tied to a liquidation into a tax-exempt tribal entity.
183 million; after concluding the claimed value was inflated by a jaw-dropping $178 million. The court’s opinion, issued March 26, 2026, marks another decisive blow to syndicated conservation easements (SCEs), a transaction the IRS has long branded as an abusive tax shelter.
The Tax Court has delivered a stark reminder to taxpayers: undocumented basis claims are a losing bet. In Tibor Gyarmati v. C. Memo.
The Tax Court just handed down a landmark ruling that could reshape the microcaptive insurance industry; one that wipes out $1,099,900 in claimed deductions, slaps the taxpayers with a 40% accuracy-related penalty, and asserts sweeping authority over a tax structure Congress explicitly incentivized.
The stakes could not have been higher when the Tax Court denied a motion to dismiss a $45 million dispute over a conservation easement deduction; one that, if allowed, would have erased nearly $45 million in claimed charitable contributions, plus a 20% accuracy-related penalty...
The Tax Court’s December 16, 2025 ruling in Mission Organic Center, Inc. v. Commissioner delivered a stark warning to state-legal marijuana businesses: the IRS’s collection power trumps even the most aggressive settlement offers when nondeductible §280E expenses are involved.
The Tax Court’s December 18, 2025 ruling in Mark L. Fussell v. Commissioner delivers a stark warning to taxpayers who attempt to deduct loans to failed businesses as bad debts.
The stakes could not have been higher for Ignacio Montes Gonzalez and Adalberto Yanez Alvarenga when the Tax Court delivered its final ruling in their case.
9 million refund demand. At issue is whether Carl Barney’s transfer of his for-profit college empire to a nonprofit entity in 2012 was a legitimate bargain sale under Section 170; the charitable contribution deduction statute; or a disguised sale designed to avoid capital gains tax.
The Tax Court’s December 30, 2025 ruling in Estate of Georgia M. Spenlinhauer delivers a stark warning to executors and heirs: missed deadlines and overlooked elections can trigger millions in unpaid taxes, penalties, and transferee liability. 5 million at stake.
S. Tax Court delivered a stark reminder to high-net-worth taxpayers this week, denying a $188,563 charitable deduction claimed by Luke and Breeana Gibson for donated "high-end cycling apparel" due to a complete failure to substantiate the donation’s basis and fair market value.
The stakes couldn’t have been clearer: the IRS revoked the Milk Saving Starving Children Foundation’s 501(c)(3) tax-exempt status effective July 1, 2017, leaving the foundation liable for $26,447 in unrelated business income tax for 2018; with no charitable expenditures to offset it.
The stakes couldn’t have been higher when Todd A. Crawford, a small-business owner, found himself staring down a $28,977 Trust Fund Recovery Penalty (TFRP) liability for unpaid payroll taxes.
The Tax Court’s January 7, 2026 ruling in Dunn v. C. Memo. 2026-2) exposes a harsh reality for taxpayers navigating Collection Due Process (CDP) hearings: a procedural misstep can erase all leverage, even when no tax is owed.
The stakes couldn’t have been higher: $20,904 in disputed tax liability hinged on whether the IRS could bypass a fundamental safeguard in the tax code. S.