The IRS granted an extension to file a Section 336(e) election after the taxpayer requested relief under Treas. Reg. 9100-3 for a late filing. The agency concluded the parties acted reasonably and in good faith, waiving the late election penalty.
S. citizen before the estate’s administration concluded. The ruling preserved a $X million marital deduction that would have otherwise been lost due to the late conveyance of trust assets.
The IRS granted late election relief to an S corporation seeking to change its tax year-end after missing the filing deadline for Form 1128, the application to adopt, change, or retain a tax year.
The IRS has issued a final ruling denying tax-exempt status for two specialized military vehicles, potentially exposing defense contractors to a 12% federal excise tax (FET) on their first retail sales.
The IRS granted a non-precedential private letter ruling (PLR-110907-25) extending the deadline for a surviving spouse to elect qualified domestic trust (QDOT) treatment under § 2056A(d) after her tax professional failed to advise her of the Form 706 filing requirement. S. citizen spouse.
0 Act permits qualified long-term care distributions (QLTCDs) from defined contribution plans (401(k), 403(b), governmental 457(b)) for certified long-term care insurance premiums without violating plan qualification requirements.
The stakes couldn’t be higher in Paschall v. Commissioner—a case that could force crypto investors to rewrite their tax strategies.
715 million for the Yosts—valuing the easements at just $649,955 and imposing 40% gross valuation misstatement penalties.
The IRS has approved a proposed corporate restructuring as a tax-free spin-off under Section 355 and Section 368(a)(1)(D) of the Internal Revenue Code, according to a recently issued private letter ruling (PLR-119258-25).
9100-3 to four taxpayers (A, B, C, and D) who inadvertently missed the deadline to file Form 8832, the entity classification election to be treated as disregarded entities.
9100-3 to a taxpayer seeking to elect Qualified Subchapter S Subsidiary (QSub) status for a subsidiary, allowing the election to be effective as of Date 2. The taxpayer must file Form 8869 with the appropriate service center and include a copy of this Private Letter Ruling (PLR-116311-25).
The IRS granted a 120-day extension to file Form 8832 to retroactively elect disregarded entity status, despite the taxpayer’s $0 cost mistake. 9100-3.
A taxpayer’s complex web of trusts—designed to benefit descendants—accidentally triggered $10 million-plus in unintended GST exemption allocations after professional advisors failed to recognize the automatic allocation rules under Section 2632(c)(1) of the Internal Revenue Code.
The IRS has issued a favorable private letter ruling (PLR-113827-25) blessing proposed modifications to a pre-1985 irrevocable trust, confirming four critical tax outcomes: the trust’s continued exemption from generation-skipping transfer (GST) tax under § 2601, the absence of a...
The IRS ruled in PLR-113817-25 that a partnership’s receipt of diversified investment assets would not trigger gain recognition under § 721(a), despite the partnership’s potential status as an investment company under § 721(b).
D. 10048 that streamline information reporting obligations for partnerships selling certain partnership interests. Effective immediately, partnerships are no longer required to furnish computational information to partners by January 31 of the year following the sale or exchange.
The Tax Court granted summary judgment in favor of the IRS, upholding deficiencies and penalties exceeding $250,000 for tax years 2011–2013 against serial tax evader Adam Shryock. The ruling bypassed trial entirely due to Shryock’s failure to contest critical allegations.
S. Tax Court delivered a stark reminder to taxpayers on May 27, 2026, when it upheld a $22,383 deficiency against Sang Hun Lee after he failed to substantiate claimed business expenses. The court’s ruling—issued in Lee v. C. Memo.
In Fuhai Li and Hong Hu v. S. Tax Court addressed the interplay between criminal convictions and civil tax fraud penalties. The IRS assessed deficiencies of $292,170 and fraud penalties of $225,877 under Section 6663 for tax years 2011–2013. The court ruled that Mr.
7701-3, to retroactively be treated as a corporation for federal tax purposes. The IRS granted the extension, though the ruling remains non-precedential.
9100-3 of the Procedure and Administration Regulations. 9100-3 provides discretionary relief for regulatory elections filed outside prescribed deadlines. The effective dates for both elections remain unchanged, preserving the taxpayer’s intended tax treatment retroactively.
The IRS has approved a proposed transaction where an S corporation (Distributing) spun off a subsidiary (Controlled) to a shareholder (Shareholder D) in exchange for their stock in Distributing.
The IRS granted § 9100 relief to a taxpayer who missed the deadline to self-certify as a Qualified Opportunity Fund (QOF) for Year 1, allowing retroactive certification after a miscommunication between the taxpayer’s controller and tax advisor led to the omission of Form 8996.
9100-3 for a partnership to file a late § 754 election after the partnership inadvertently missed the deadline due to oversight.
The IRS ruled in favor of the taxpayer on all four requested rulings, allowing the surviving spouse to treat the IRA proceeds as her own and roll them over into her own IRA within 60 days.
The IRS has ruled that periodic payments under an indexed structured settlement annuity contract meet the "fixed and determinable" requirement of § 130(c)(2)(A) and qualify as a "qualified funding asset" under § 130(d).
The IRS has ruled that indexed structured settlement annuities—contracts with payments tied to market performance but featuring a guaranteed minimum—can qualify as "qualified funding assets" under § 130 of the Internal Revenue Code.
The Internal Revenue Bulletin (IRB) No. 2026–22, issued May 26, 2026, delivers a sweeping array of administrative, procedural, and legislative updates that will reshape tax compliance, planning, and enforcement for practitioners across industries.
The stakes could not have been higher for Bryan Edward Menge.
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...