A Real Estate Investment Trust (REIT) stood to lose a $a capital gain deduction in Year 1 when a dividend declared in Year 2 was mistakenly omitted from its timely filed tax return.
The IRS granted relief under § 1362(f) to an S corporation whose election terminated after ineligible trusts failed to file Electing Small Business Trust (ESBT) elections under § 1361(e).
On August 20, 2026, the IRS issued a private letter ruling (PLR-118845-25) confirming that a state university’s partnership with a biopharmaceutical firm to develop radioisotopes for life-threatening diseases does not trigger unrelated business income tax (UBIT).
The IRS granted a 120-day extension to a taxpayer seeking to file an amended Form 8609 to correct a missed average income election under Section 42(g)(1)(C) of the Internal Revenue Code, preserving potential low-income housing credits exceeding $5 million over the 10-year credit period.
9100-3 to a partnership that inadvertently omitted the election statement required to opt out of bonus depreciation under § 168(k).
The IRS has approved a taxpayer’s methodology for calculating overlapping public group ownership in a cross-border acquisition, providing a non-precedential roadmap for preserving net operating loss (NOL) carryforwards under Section 382 of the Internal Revenue Code.
The stakes could not have been higher. The Internal Revenue Service had just wrapped up a multiyear crackdown on abusive tax shelters that ultimately yielded billions in collected proceeds—a haul so large it redefined the agency’s enforcement posture toward corporate tax avoidance.
The stakes in this case could not be higher: the Internal Revenue Service has asserted deficiencies totaling $1,648,940 across tax years 2009 through 2014, along with $486,453 in accuracy-related penalties under § 6662(a). These figures represent not just a financial reckoning for Frank L.
The Tax Court has delivered a stinging rebuke to an IRS revenue agent who claimed nearly $60,000 in questionable tax deductions while auditing his own returns. In a rare judicial takedown of a tax professional, the court ruled that Peter J.
The IRS has ruled that a partnership return containing only ownership information and all zeros is invalid under the Beard test, concluding the filing fails to provide sufficient data for tax calculation.
C. §§ 1311–1314 may permit reopening a closed tax year to recover $X million in erroneously claimed double credits for research (§ 41) and work opportunity (§ 51) tax benefits.
The IRS formally denied a partnership’s request for relief under Section 9100 to validate a Bipartisan Budget Act (BBA) push-out package, citing two procedural failures: the package was submitted in the wrong format and included incomplete Forms 8986.
The IRS has determined that USP’s aggregate foreign cash position (AFCP) was underreported by $18 million (Amount 1) in its Section 965 transition tax calculation, while a $13 million negative cash balance (Amount 2) could not offset the cash positions of its specified foreign corporations (SFCs).
The stakes were high when six trusts holding shares in an S corporation failed to file timely elections to qualify as Electing Small Business Trusts (ESBTs), triggering an inadvertent termination of the corporation’s S election under § 1362(f).
9100-3(c) to a foreign entity that inadvertently failed to timely file Form 8832, Entity Classification Election, to be treated as a disregarded entity for federal tax purposes.
9100-3 to an estate seeking to elect portability under § 2010(c)(5)(A), allowing the surviving spouse to claim the decedent’s deceased spousal unused exclusion (DSUE) amount.
9100-3 to a decedent’s estate for a late portability election under § 2010(c)(5)(A), permitting the surviving spouse to claim the deceased spousal unused exclusion (DSUE) amount.
The IRS granted relief under § 1362(f) of the Internal Revenue Code to a taxpayer whose Form 2553 election to be treated as an S corporation was rendered ineffective due to an inadvertent filing error.
7701-3, allowing it to retroactively elect corporate tax treatment effective Date 1. The taxpayer, a State limited liability company formed on Date 1, had intended to be taxed as a corporation but failed to file the required form by the statutory deadline.
The IRS granted a taxpayer’s request for an extension to make a late average income minimum set-aside election under § 42(g)(1)(C) of the Internal Revenue Code, allowing the taxpayer to file an amended Form 8609 within 120 days of the ruling.
9100-3 of the Procedure and Administration Regulations to a taxpayer who sought to make a late election to change its taxable year via Form 1128.
The IRS granted relief under § 1362(f) to a limited liability company (LLC) that inadvertently failed to qualify as an S corporation due to multiple compliance errors, including missing shareholder consents and operating agreement provisions that created a second class of stock.
The IRS granted consent to a taxpayer seeking to switch from the default method to the elective method for measuring and timing stock-based compensation (SBC) in its cost-sharing arrangements (CSAs), effective only for SBC granted in taxable years after the consent is obtained.
The Internal Revenue Bulletin No. 2026–35, published on August 24, 2026, introduces a series of consequential updates spanning energy incentives, estate tax valuation, retirement savings, and administrative procedures.
The U.S. Tax Court on Thursday partially sustained and partially remanded the IRS’s collection determinations in a case involving $500,000 in unpaid trust fund recovery penalties (TFRPs), ruling that the agency failed to verify that levy notices were mailed to the taxpayer’s...
S. 10 in unpaid employment taxes, penalties, and frivolous litigation sanctions. The liability stems from Forms 940 (FUTA tax) for 2009 and 2013–2019, Forms 941 (payroll tax) for 2014–2021, and § 6721 penalties for late filings.
S. Tax Court has delivered a decisive blow to former CPA James H. C. Heyde, ruling that their execution of Form 870–LT in a prior TEFRA partnership audit permanently precludes them from challenging $83 million in disallowed net operating loss (NOL) carryforwards for tax years 2016 and 2017.
The stakes couldn’t have been higher when attorney Percy Squire squared off against the IRS in Percy Squire v. C. Memo. 2026-71 (Aug. 19, 2026).
The Tax Court’s ruling in Tabaka v. C. Memo. 2026-70, delivered a clear message to taxpayers seeking abatement of IRS interest charges: the bar for relief is extraordinarily high.
C. Memo. 2026-69) threatens to upend the tax planning strategies of social media influencers nationwide, imposing $130,550 in deficiencies and $26,110 in penalties for tax years 2019–2021.