The Internal Revenue Service on September 8, 2026, unveiled proposed regulations under Internal Revenue Code § 125 that would allow employers to contribute up to $2,500 annually to employees’ or their dependents’ “Trump accounts,” a newly codified tax-advantaged savings vehicle.
The IRS granted a taxpayer’s request to make a retroactive qualified electing fund (QEF) election under Section 1295(b) and Treas. Reg. 1295-3(f) for Year 1, despite missing the original filing deadline.
9100-3 to a corporate parent group seeking to file a consolidated return election for tax years ending Date 1 and subsequent years. 1502-75(a)(1), which governs consolidated return elections.
The IRS granted relief under § 1362(b)(5) of the Internal Revenue Code to a taxpayer who filed a late S corporation election, allowing the corporation to be treated as an S corporation retroactively.
9100-1 to a taxpayer who missed the deadline to file a duplicate Form 3115, Application for Change in Accounting Method, due to a fax transmission failure.
7704-1(g) of the Income Tax Regulations, allowing partnerships to avoid classification as publicly traded partnerships (PTPs) under § 7704 of the Internal Revenue Code.
9100-3 after a courier service failed to deliver the extension request on time.
A taxpayer’s Real Estate Investment Trust (REIT) and Real Property Trade or Business (RPTOB) elections were nearly invalidated after a courier service failed to deliver a critical extension request on time.
The stakes couldn’t have been higher: a taxpayer stood to lose a $10 million REIT election and the associated tax benefits because a courier inexplicably failed to deliver a time-sensitive extension request.
A taxpayer’s attempt to elect Real Estate Investment Trust (REIT) status and a related Real Property Trade or Business (RPTOB) election hung in the balance after a courier service failed to deliver its tax filings on time, risking the loss of millions in tax benefits.
9100-3 to a taxpayer seeking extensions for late elections under § 856(c) (REIT status) and § 163(j)(7)(B) (RPTOB election), despite the filings being delayed due to a courier’s failure to deliver documents on time.
A taxpayer’s $5 million+ Qualified Opportunity Fund (QOF) election was nearly invalidated after an accounting firm incorrectly filed Form 8996, the IRS disclosed in a private letter ruling (PLR-120036-25). 9100-3 to correct the error, allowing the QOF election to stand.
The IRS granted a 120-day extension under Treas. Reg. S. citizenship change. The trustee’s delay stemmed from unawareness of the spouse’s naturalization, which occurred after the decedent’s estate elected Qualified Domestic Trust (QDOT) treatment under IRC § 2056A(a).
The IRS granted a 120-day extension for a partnership to file a late § 754 election after two partners died, citing the partnership’s reasonable actions and no prejudice to government interests.
9100-3 to an estate that missed the deadline to elect portability of a deceased spouse’s unused exclusion (DSUE) under § 2010(c)(5)(A). The estate, which was not required to file Form 706 under § 6018(a), sought to preserve the DSUE amount for the surviving spouse.
9100-3 for a taxpayer’s missed reverse QTIP election under § 2652(a)(3), preserving the estate’s Generation-Skipping Transfer Tax (GSTT) exemption and avoiding potential liability exceeding $10 million. 9100-3.
The Tax Court’s September 3, 2026 ruling in Merida Ortiz v. Commissioner (Docket No. 13093-25) delivered a stark message to millions of ITIN filers: the $1,400 2021 Economic Recovery Rebate Credit under Section 6428B is off-limits to anyone without a Social Security Number.
The stakes in this case were not measured in dollars but in the very authority of the Tax Court to review an IRS decision that could leave a taxpayer on the hook for a spouse’s tax debts.
The stakes could not have been higher in Hank Risan, et al. v. Commissioner, filed in the United States Tax Court on September 2, 2026.
The Tax Court’s final reckoning with Myrna Marin arrived on September 2, 2026, in a blunt memorandum opinion that left no room for doubt: her decision to advance frivolous tax arguments had cost her $68,456.
S. Tax Court has delivered a decisive rebuke to pro se taxpayer John W. Sprouse, imposing a $217,478 deficiency for 2019, a $43,496 accuracy-related penalty under § 6662(a), and an additional $2,500 penalty under § 6673(a) for maintaining frivolous proceedings. C. Memo. 2026-80 (Docket No.
S. Tax Court has just handed the IRS a procedural victory in one of the most consequential transfer pricing disputes in recent history, denying Airbnb’s motions to strike the agency’s expert declarations while simultaneously asserting its authority to police procedural rules in discovery disputes.
The stakes could not have been higher. 3 billion in recoveries and unpaid taxes stemming from abusive digital foreign exchange option transactions—a sum that would have dwarfed every prior award in Tax Court history.
The IRS granted a 75-day extension to a taxpayer that missed a consolidated return election deadline due to a miscommunication among its management, legal counsel, and tax preparers.
9100-3 for a portability election under § 2010(c)(5)(A), allowing the estate to file a late election after determining the taxpayer acted reasonably and in good faith.
Picture a piece of software running on a server somewhere, holding its own cryptographic private key — the same kind of credential that lets a human control a crypto wallet, except here no human holds it.
9100-3 to a partnership that missed its deadline to file a § 754 election, a critical tax election that adjusts the basis of partnership property following a transfer of a partnership interest or a distribution of property.
The IRS has approved a court-approved settlement agreement dividing the Grandchildren’s Trust, confirming that the restructuring will not jeopardize its generation-skipping transfer (GST) tax exempt status under Section 2601—the 40% tax imposed on transfers to skip persons—and...
The IRS granted a 120-day extension to make a qualified terminable interest property (QTIP) election under § 2056(b)(7) after the executor of a decedent’s estate discovered an error on Schedule M of Form 706, the federal estate tax return.
The IRS granted inadvertent termination relief under § 1362(f) to a corporation that inadvertently invalidated its S election due to an ineligible shareholder and a second class of stock.