Latest US Tax Court decisions and federal tax court opinions
The Internal Revenue Bulletin No. 2026-29 introduces sweeping changes to energy tax credits, environmental taxes, and compliance requirements that demand immediate attention from tax practitioners.
S. Tax Court ruled on July 8, 2026, that the IRS had the power to correct its own mistakes—without filing a lawsuit. , after the IRS admitted it had miscalculated the company’s tax liability and issued an erroneous refund. The court’s ruling in Hough Beck & Baird, Inc. v. Commissioner, Docket No.
Thermal Circuits, Inc. just learned the hard way that the Tax Court will not rewrite the rules on customer-funded leasehold improvements—even when the customer is a $5 billion tobacco giant.
The Tax Court’s ruling in Dee delivers a dual message: a jurisdictional win for whistleblowers and a sharp reminder of the IRS’s unassailable discretion. After a decade-long battle, John R.
The Internal Revenue Bulletin No. 2026-28, issued July 6, 2026, delivers three pivotal updates reshaping pension funding calculations, federal rate applications, and Qualified Opportunity Zone (QOZ) compliance.
The IRS granted relief under § 1362(f) to S corporation X for an inadvertent failure to meet Qualified Subchapter S Subsidiary (QSub) election requirements.
The IRS granted a taxpayer’s request for a late election to be treated as a real estate investment trust (REIT) under Section 856(c) of the Internal Revenue Code, despite missing the initial filing deadline.
9100-3 to file late Form 8832, Entity Classification Election elections, allowing them to retroactively elect disregarded entity status. S. federal income tax returns consistent with their elected classification.
A CPA’s failure to properly elect Qualified Terminable Interest Property (QTIP) and reverse QTIP treatment on Form 706 nearly cost an estate $12 million in avoidable estate and GST taxes.
The IRS granted discretionary relief under § 1362(b)(1) of the Internal Revenue Code to a taxpayer who failed to timely file Form 2553 to elect S corporation status.
The IRS granted relief under § 1362(f) to an S corporation whose election terminated after its operating agreement inadvertently created multiple classes of stock, allowing the corporation to retain its S status.
The IRS has ruled that a proposed corporate spin-off qualifies as a tax-free reorganization under Sections 355 and 368(a)(1)(D) of the Internal Revenue Code, providing critical guidance for taxpayers navigating complex restructurings.
An S corporation faced potential tax liabilities exceeding $5 million after inadvertently missing deadlines to elect Qualified Subchapter S Subsidiary (QSub) status for four subsidiaries.
The IRS granted a taxpayer’s request for both an extension of time to make late Qualified Subchapter S Subsidiary (QSub) elections and relief for ineffective elections, allowing the company to avoid disqualification of QSub status for 10 subsidiaries.
The IRS granted a rare 120-day extension to a foreign company that missed the deadline to file Form 8832, the election to be treated as a disregarded entity for federal tax purposes.
The IRS granted a rare 120-day extension to a foreign company seeking to file a late Form 8832 election to be classified as a disregarded entity, citing the taxpayer’s reasonable and good-faith actions. 9100-3 are infrequent and the ruling carries no precedential weight.
The IRS granted a private foundation’s request to retroactively correct errors in treating leased property as both a qualifying distribution and exempt-use property under Section 4942, allowing the foundation to recompute its minimum investment return and qualifying distribution...
The IRS granted a 120-day extension to file Form 706, allowing a surviving spouse to claim the deceased spouse’s unused exclusion (DSUE) amount under § 2010(c)(5)(A).
The Tax Court’s decision in Edmund Ha v. 80 accuracy-related penalty for failing to meet the IRS’s strict substantiation requirements.
The Tax Court delivered a blunt reminder to high-earning entrepreneurs last month: $50,427 in claimed Schedule C deductions vanished into thin air after Gregory A. Rodrigues, a former CEO and real estate investor, failed to meet the IRS’s strict substantiation requirements. C.
S. 1 million in unpaid restitution-based assessments (RBAs) while a prior Department of Justice (DOJ) settlement was still in force. 89 million tax liability to judgment under a structured payment plan.
9100-3 to a taxpayer seeking to file a late § 168(h)(6)(F)(ii) election, allowing it to avoid unintended tax-exempt controlled entity status.
9100-3 to X, a State LLC taxed as a partnership, allowing it to file a late § 754 election for its taxable year ended Date 1.
A taxpayer nearly lost Qualified Opportunity Fund (QOF) status—and the potential tax deferrals that come with it—after a trusted tax professional overlooked a critical filing deadline.
The IRS granted rare relief to a taxpayer who missed the deadline to self-certify as a Qualified Opportunity Fund (QOF), preserving over $5 million in potential tax benefits after a tax professional failed to file Form 8996.
9100-3 of the Procedure and Administration Regulations, allowing an LLC to retroactively elect corporate tax treatment via Form 8832 effective Date 2. 7701-3. This ruling permits the LLC to avoid unintended tax consequences by validating its corporate election retroactively.
The Internal Revenue Bulletin No. 2026–27 delivered a pivotal update to the Inflation Reduction Act’s energy community bonus credits, reshaping the financial landscape for renewable energy developers.
In Frederick Whigham v. C. Memo. 18 in unpaid federal income taxes for tax years 2011, 2014, 2015, and 2017.
S. Tax Court delivered a landmark ruling in Hee v. N. Hee and his closely held corporation, Waimana Enterprises, Inc.
The stakes in Charlton C. Tooke III v. 8 million in unpaid federal taxes spanning tax years 2012 through 2017. At issue is whether the IRS abused its discretion in rejecting Tooke’s Offer-in-Compromise (OIC) and sustaining a Notice of Federal Tax Lien (NFTL) and proposed levy actions.