Latest US Tax Court decisions and federal tax court opinions
A public utility sought IRS guidance on whether extraordinary costs incurred due to a coal supply disruption could qualify for tax-exempt bond financing under strict arbitrage rules. 148-10(a)(4), which prohibits overburdening the tax-exempt bond market.
The IRS granted relief under § 1362(f) to a corporation whose S election was inadvertently terminated when the beneficiary of a trust holding its shares failed to file a Qualified Subchapter S Trust (QSST) election under § 1361(d)(2).
1502-75(a)(1), ruling that the taxpayer’s failure to timely elect was excusable due to reasonable reliance on a tax professional who omitted the election entirely.
9100-3 to a taxpayer who missed the deadline to file Form 8949 to elect capital gains deferral under Section 1400Z-2(a)(1)(A).
The IRS granted a 120-day extension to an estate that missed the deadline to elect portability under § 2010(c)(5)(A), allowing the surviving spouse to claim the decedent’s unused estate tax exclusion (DSUE).
The IRS ruled in PLR-119317-25 that a portion of indebtedness ($L) incurred by Old Parent and traced to contributions for a specific purpose (Purpose M) qualifies as "ordinary course" indebtedness under § 382(l)(5)(E)(ii), preserving the bankruptcy exception to ownership change limitations.
9100-3 to an estate that failed to make a QTIP election under § 2056(b)(7) and a reverse QTIP election under § 2652(a)(3), averting a potential $5 million-plus estate tax liability and Generation-Skipping Transfer (GST) tax exposure.
The Internal Revenue Bulletin for August 17, 2026, introduces critical updates to the Employer Credit for Paid Family and Medical Leave under Section 45S of the Internal Revenue Code, as amended by the One, Big, Beautiful Bill Act (OBBBA, Pub. L. 119-21, 139 Stat. 72, July 4, 2025).
The stakes could not have been higher for Jeffery Dieffenbach, a licensed attorney who faced a staggering $72,403 in tax deficiencies and penalties for tax years 2015 through 2019. S. Tax Court, in a memorandum opinion filed August 13, 2026 (Dieffenbach v. C. Memo.
S. Tax Court issued its decision on August 12, 2026, in Deutsch v. C. Memo. 2026-66.
The Tax Court’s August 11, 2026 ruling in Gerald A. Beacom and Jean A. Beacom v. C. Memo. 40 accuracy-related penalty for failing to substantiate a decade-long alternative minimum tax (AMT) credit.
S. Tax Court issued its summary opinion in Aimiuwu v. C. Summary Opinion 2026-7, filed August 10, 2026).
The stakes couldn’t have been higher: a Real Estate Investment Trust (REIT) faced potential disqualification and a seven-figure tax bill after its tax advisor missed a critical election deadline.
9100-3 to retroactively elect to treat a subsidiary as a Taxable REIT Subsidiary (TRS) under Section 856(l) of the Internal Revenue Code. The IRS granted the relief, allowing the subsidiary to be treated as a TRS effective as of the originally intended date.
The IRS granted a private letter ruling (PLR-119898-25) allowing a real estate investment trust (REIT) to retroactively elect its subsidiary as a taxable REIT subsidiary (TRS) under Section 856(l) of the Internal Revenue Code, despite missing the filing deadline.
7701-3(c)(1)(iv). The taxpayer’s request hinged on a change in ownership exceeding 50%, which the IRS determined justified the exception. This ruling signals broader flexibility for taxpayers seeking relief from the rule’s strict time constraints.
7701-3, which governs how eligible business entities elect their federal tax classification.
9100-3 to a foreign entity that missed the deadline to file Form 8832, the election to be treated as a disregarded entity for federal tax purposes.
The IRS granted X a 120-day extension to file Form 8832, Entity Classification Election, to elect partnership status, effective as of the originally intended date.
A mislabeled structure chart and advisor oversight nearly cost a Real Estate Investment Trust (REIT) and its subsidiary $5 million in potential disqualification and tax liabilities after a late election to treat the subsidiary as a Taxable REIT Subsidiary (TRS) under IRC § 856(l).
The IRS has granted a 120-day extension to an estate seeking to make a portability election under § 2010(c)(5)(A), preserving the surviving spouse’s ability to claim the deceased spouse’s unused estate tax exemption (DSUE).
7701-3. The relief, issued in PLR-119526-25 on [Date 2], permits the taxpayer to file the election within 120 days of the ruling’s date, contingent on filing all required tax returns within that period.
In a rare act of leniency, the IRS granted a 120-day extension under Section 2642(g) of the Internal Revenue Code to a taxpayer who missed the deadline to elect GST trust treatment under Section 2632(c)(5)(A)(ii).
The IRS granted relief under § 1362(f) of the Internal Revenue Code to X, an S corporation, after a trust holding its stock failed to file a required Electing Small Business Trust (ESBT) election under § 1361(e).
A taxpayer narrowly avoided a $5 million generation-skipping transfer (GST) tax liability after the IRS granted a 120-day extension to correct a missed election under Section 2632(c)(5)(A)(ii) of the Internal Revenue Code.
7701-3, which governs entity classification elections. 9100-3, which allows discretionary extensions for regulatory elections when taxpayers act reasonably and in good faith without prejudicing the government.
The IRS has issued a private letter ruling (PLR-111478-25) confirming that a proposed division and modification of an irrevocable family trust—approved by a state court on Date 6—will not trigger generation-skipping transfer (GST) tax, gift tax, or income tax consequences.
1502-75(a)(1), the regulation governing elections to file consolidated federal income tax returns for affiliated groups. The relief was conditioned on the group’s tax liability not being lower than if the election had been timely made.
The IRS granted a partnership a 120-day extension to retroactively file a § 754 election after the partnership missed the deadline due to an inadvertent oversight.
The IRS has approved a taxpayer’s revised schedule of ruling amounts for a nuclear decommissioning reserve fund under § 468A(d)(1), allowing a formula-based approach to calculate annual contributions while ensuring compliance with the statute’s strict timelines.