PODCAST · business
Current Federal Tax Developments
by Edward Zollars, CPA
Weekly update on federal income tax developments
Episodes
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2026-10-05 Trump Accounts Established for All Children
This week we look at: Informal claim and COVID-19 disaster relief save an untimely-looking IRA refund suit in Singh. IRS recasts “Section 351 conversion” ETF transactions as taxable exchanges in Rev. Rul. 2026-20. Proposed regs implement a four-year installment election for farmland sales to…
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2026-09-28 Estate Closing Letter Fee Increase Finalized
This week we look at: Tax Court Applies Equitable Tolling to BBA Partnership Petition Deadlines -- Kings Road Property District Court Voids VIBIR's Net Investment Income Tax Assessment -- Perkins IRS Notice 2026-55 Seeks Comments on Opportunity Zone Rules for Housing Developers Hurricane Michael...
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2026-09-21 Tax Break for Preschool Teachers in the Russia Sanctions Bill
This week we look at: Tax Court Warns of AI Drafting Pitfalls in a CDP Lien Withdrawal Case -- Moore Altering the Perjury Jurat Dooms a Refund Suit -- Johnson v. IRS IRS Extends the Involuntary Conversion Period for Drought-Hit Livestock Sales H.R. 9500 Would Restore and Expand Personal Casualty...
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2026-09-14 The Picasso and the Income
This week we look at: Final Regulations Restore the Car Loan Interest Deduction Under T.D. 10054 Fourth Circuit Affirms $2.9M Willful FBAR Penalty -- United States v. Rund Tax Court Clarifies BBA Extension Mechanics -- Katanga Properties Treasury Proposes Sweeping QOF Certification and Reporting...
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2026-09-07 IRS Bit By Not Mailing Via Certified Mail
This week we look at: Federal Circuit Bars Treaty FTCs Against the NIIT -- Bruyea and Christensen Financial Disability Tolling and Third-Party Authorization -- Goldman v. United States OIC Public-Policy Rejections Upheld -- Filipowski v. Commissioner Substantiation and Alter-Ego Doctrine -- Hank...
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2026-08-31 When is a Partnership Return Not a Return
This week we look at: Zero-Return Form 1065 Filings and the Beard Test (IRS CCA 202634014) Full Payment Rule & Presumption of Correctness -- Pellegrino v. United States Pro Rata Share Determinations Under OBBBA -- Proposed Regulations (REG-115646-25) Treaty Exclusivity for Pooled Investments --...
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2026-08-24 Proposed Regulations Week
This week we look at: Form 1041-A Relief for Passthrough Charitable Deductions (REG-109082-25) Vested Development Rights & Easement Valuation — Malibu Valley Land v. Commissioner First Circuit Bars Equitable Tolling of Section 6213(a) — Kyick Holdings v. Commissioner PRWORA Immigration…
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2026-08-17 Maybe State Law Limited Partner Isn't the Test for 1402(a)(13)
This week we look at: Unpacking the Saver’s Match: Technical Guidance and Operational Frameworks Under Notice 2026-48 Harmonizing Section 3406 Backup Withholding with Section 6050W De Minimis Reporting Thresholds The High Bar for Equitable Tolling in Tax Practice: The Eighth Circuit’s Final…
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2026-08-10 IRS Guidance on Qualifed Overtime for 2026-2028
This week we look at: Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4) Trustee-to-Trustee Transfers of Inherited IRAs Through an Estate: Technical Analysis of PLR 202631001 Federal Courts Lack APA Jurisdiction Over Foreign Gift...
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2026-08-03 On Again Off Again On Again PLR
This week we look at: IRS Reinstates Tax Deferral on Variable Annuity Term Certain Options: Reconsideration and Reversal in PLR 202630002 Understanding the ERC Pleading Standard: Federal Claims Court Deferral in I Health and Life Insurance Services Predecessor Losses, the Lonely Parent Rule, and...
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2026-07-27 AICPA New Interpretation on Indepdendence and Tax Engagements
This week we look at: Valuation of Remainder Interest Gifts Upon Trust Termination: State Law and Net Gift Adjustments in Lewis v. Commissioner Revenue Procedure 2026-26: Technical Overview of 2027 Indexing Adjustments for Premium Tax Credits and Affordability Standards Limitations of Interest...
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2026-07-20 IRS Expands Business Tax Accounts
This week we look at: Partnership Recourse Rules: Conditional DROs will not establish EROL under § 1.752-2. Mileage Rate Adjustment: Business standard mileage rate rises to 76 cents on July 1, 2026. Business Tax Account: Modernized self-service portal expands features but requires active annual...
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2026-07-13 A Week of Final Regulations
This week we look at: Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP) Strict Enforcement of Tax Refund Statutes of Limitations Employee Retention Credit (ERC) Refund Claims & Pleading Standards Pandemic-Era Persistence of New York's Convenience of the Employer...
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2026-06-22 Qualified Opportunity Zone Interim Guidance for OBBBA
This week we look at: Relief from Ineffective S Corporation and QSub Elections Procedural and Jurisdictional Limits in Challenging IRS Guidance Medicaid Gross Receipts, Cohan Estimations, and Professional Reliance Standards and Deceit in Supervised Release Transitional Guidance on Qualified...
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2026-07-06 ERC Cases Galore Week
This week we look at: Section 7508A(d) and Interest on Pre-COVID-19 Disaster Tax Deficiencies The Soroban Capital Partners SECA Tax Controversy Pleading Requirements for the Employee Retention Credit (Tapestry Senior Housing) ERC Causation and the Essential Business Hurdle (RAAM Construction) The...
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2026-06-29 OPR Releases Guidance On use of Generative AI
This week we look at; Nominal S Corporation Ownership and the Abuse Exception Recapping the ERC via Section 7405 Civil Actions Constructive Dividends, Formalities, and Civil Fraud CDP Hearings, Offer-In-Compromise, and RCP Calculations Professional Responsibility and Responsible AI Use Rigorous...
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2026-06-15 Trusts and the New Section 68
A discussion of the impact of new Section 68 on trusts and the JCT's Blue Book Footnote 102, IRS previews upcoming Section 25F credit guidance and more.
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2026-06-08 An Inconsistent Tale of Two ERC Court Rulings
Two decisions on the ERC and what is a partial suspension completely disagree on the level of causation that must be shown related to a government order, yet another conservation easement taxpayer loss and more.
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2026-06-01 More Details on the Activation of Trump Accounts
This week we look at: Procedural Timeliness & Automatic Extensions Spousal IRA Rollovers Through Estates and Trusts Collateral Estoppel and the "Innocent" Spouse Improper Corporate Deductions and Fraud Implementation of "Trump Accounts" 2027 Inflation Adjustments (HSA, HRA, DPCSA) An audio only...
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2026-05-25 IRS Prepares to Challenge Kwong After Limited AOD on Abdo
IRS (barely) acquiesces in case of Abdo but will appeal Kwong, House passes an bill to reverse Supreme Court's Zuch decision and more.
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2026-05-18 If a Client Claims Charitable Contributions You Must Understand the CWA Rules
Failure to follow CWA rules eliminate all of a charitable contribution deduction, IRS announces syndicated conservation easement settlement initiative, and more.
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2026-05-11 The Expensive Lost White Receipt and Certified Mailing
Yet another syndicated conservation easement taxpayer loss in Tax Court, the FTB loses an attempt to tax an out of state physician and more.
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2026-05-04 Treasury Previews Upcoming 280E Medical Marijuana Guidance
Treasury and IRS previews medical marijuana Section 280E guidance upcoming, the House passes 9 bipartisan tax bills, ERC statute of limitations extension guidance for refund claims and more
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2026-04-27 No More 280E for State-Legal Medical Cannabis Businesses
DEA rescthedules state-legal medical marijuana, but recreational cannabis stays on Schedule III (and 280E issues continue for those businesses), Seventh Circuit finds claim of right can be used to exclude income from taxation and more.
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2026-04-20 Final Regulations Issued on Qualified Tip Income
IRS releases final regulations on qualified tip income, taxpayer finds that getting no cash from a surrendered life insurance policy doesn't necessarily mean no tax issues and more.
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2026-03-23 Claim of Right and the Correct Tax Year
Claim of right issue dooms ability to offset repayment of social security benefits, ERC litigant loses case on appeal and more.
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2026-03-16 Trump Account Proposed Regulations
IRS issues proposed regulations on Trump Account and the pilot program and the Tax Court looks it issues with an IRS notice in a BBA case.
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2026-03-09 Sir You Are About to Lose Your Passport
Two cases outline failed attempts to attempt to remove the block on access to their passports, auto depreciation limits for 2026 and more.
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2026-03-02 Another Circuit Find IRS Has Assessment Authority for Section 6038(b) Penalties
Another Circuit rules that the IRS does have the authority to assess §6038(b) penalties, delay announced in effective date for SECURE 2.0 RMD regulations and more.
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2026-02-23 Supreme Court Strikes Down Tariffs
Supreme Court overturns tariffs, IRS released interim guidance on Section 168(n) 100% bonus depreciation for qualified production property and more.
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2026-02-16 Hallucinations Enter the Tax Court
Attorney called out for suspected AI hallucinated cases by the Tax Court, First Circuit may be considering a method to avoid ruling on SE status or limited partners and more.
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2026-02-09 Another Former Spouse Ends Up With a Jackpot When Her Ex-Spouse Dies Due to ERISA
A lesson in making sure your beneficiaries are updated in ERISA covered plans following a divorce, the iRS issues guidance attacking a Charitable LLC shelter and more.
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2026-02-02 Paper Refund Checks-Notices and Patience Now
IRS issues guidance on tax refunds notices for taxpayers who don't provide bank account information, taxpayers successfully overcome presumption of delivery of a Notice of Deficiency and more.
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2026-01-26 Court Allows ERC Claim to Go Forward-But Throws Out APA Challenge
ERC suit allowed to move forward without having a specific government order identified in filing but APA challenges thrown out, the IRS issues an FAQ on the OBBBA overtime deduction and more.
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2026-01-19 Fifth Circuit Reverses Tax Court on SE Income for State Law Limited Partners
Fifth Circuit throws out functional test on self-employment income for a limited partner, IRS restarts group tax exemption process and more.
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2026-01-12 IRS Announces Opening of E-Filing Season for Individuals
IRS announces January 26 as the start date for electronic filing for individual returns, IRS found to make a procedural error in a premium tax credit case and more.
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2026-01-05 Proposed Regulations on New Car Loan Interest Deduction
IRS releases proposed regulations on vehicle interest, standard mileage rates for 2026 published and more.
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2025-12-29 Marijuana Rescheduling Restarts After Long Pause
Marijuana rescheduling proposed regulation finalization moves back into the fast lane after a year, which would remove §280E as an issue for cannabis businesses and two update Fact Sheets for OBBBA changes.
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2025-12-22 Initial Scholarship Granting Organization Guidance Issued
IRS releases initial guidance on Scholarship Granting Organizations (SGO) in preparation for 2027 tax credits, OICs and cannabis businesses and more.
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2025-12-15 Postmark Date Risk Due to USPS Change
USPS issues rules on when postmarks are applied that may make it more likely for items to be tagged as late filed, guidance on OB3 HSA expansion and more.
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2025-12-08 Initial Details Released on Trump Accounts
IRS publishes preliminary guidance on Trump Accounts and the tax credit for Scholarship Granting Organizations (SGOs).
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2025-12-01 IRS Gives First Discussion of Upcoming Credit for Donation to Tuition Organizations
IRS discusses future guidance on federal scholarship tax credit, Tax Court deals a loss to another syndicated conservation easement and more.
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2025-11-24 Tips and Overtime Form 1040 Reporting Reiief
IRS releases guidance for recipients of qualfiied tips and qualified overtime for 2025 Forms 1040, Medicare numbers for 2025 released and more.
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2025-11-17 Retirement Plan and IRA Inflation Numbers
This week we look at: Annual Adjustments to Retirement Plan Limitations Ensuring Investment Trust Status for Digital Asset Staking Entities Examining Penalties in Microcaptive Transactions Ownership Requirements for Non-Business Theft Losses Defining the Scope of I.R.C. § 172(b)(3) Carryback...
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2025-11-10 Employer Guidance for 2025 Qualified Tips and Overtime
IRS provides relief to employers for reporting on qualified overtime and tips for 2025, more conservation easement cases, and more.
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2025-11-03 Qualifying Offers in Tax Disputes
A taxpayer gets legal fees awarded due to the proper use of a qualifying offer, Congress has a bill to send to the President and more.
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2025-10-27 More IRS Government Shutdown Clarifications
IRS outlines more information on the government shutdown and what activities are affected, more FAQs for OBBBA changes and more.
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2025-10-20 Who Owns a Hotel's ERTC Refund?
Bankruptcy trustee retrieves ERTC refund from management company that was employee's employer for tax purposes, IRS finds CDP case sent back to Appeals and more
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2025-10-13 2026 Tax Year Inflation Numbers Published
IRS releases inflation adjusted amounts for 2026 tax years, IRS shutdown moves to phase two and more.
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2025-09-29 The End of Individual Refund Checks Approaches
IRS announces the beginning of the end for paper check refunds, a taxpayer loses on a hobby loss case and more.
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ABOUT THIS SHOW
Weekly update on federal income tax developments
HOSTED BY
Edward Zollars, CPA
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Current Federal Tax Developments currently has 100 episodes available on PodParley. New episodes are automatically indexed when they're published to the podcast feed.
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Weekly update on federal income tax developments
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Current Federal Tax Developments has 100 episodes. Check the episode list to see recent publication dates and frequency.
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