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Federal Tax Update Podcast

by The Ohio Society of CPAs

Federal Tax Update Podcast Series

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Episodes

  1. 2026-10-05 Trump Accounts 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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  2. 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...

  3. 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...

  4. 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...

  5. 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...

  6. 2026-08-31 When is 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 --...

  7. 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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  8. 2026-08-17 Maybe State Law Limited Partner Isn't the Test for 1402a13

    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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  9. 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...

  10. 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...

  11. 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...

  12. 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...

  13. 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...

  14. 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...

  15. 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...

  16. 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...

  17. 2026-06-15 Trusts and the New Section 68

    This week we look at: Application of New Section 68 to Trusts and Estates Assessing the Risks of Hindsight in Late § 475(f)(1) Elections The Eradication of the 5% Safe Harbor (Clean Energy) Limits of § 2036(a) and Tax-Motivated Transfers Section 183 Hobby Losses & Penalties New Section 25F...

  18. 2026-06-08 An Inconsistent Tale of Two ERC Court Rulings

    This week we look at: Proposed Increase to Estate Tax Closing Letter User Fee Divergent Causation Standards for ERC Eligibility Valuation Extremes in Conservation Easements Substantiating Mortgage Interest Deductions Taxation of Cryptocurrency Staking Rewards Section 4960 and "Covered Employees"...

  19. 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)

  20. 2026-05-25 IRS Prepares to Challenge Kwong After Limited AOD on Abdo

    This week we look at: Equitable Relief for Erroneous Tax Refunds: An Analysis of the Fourth Circuit's Reversal in LaRosa v. Commissioner Final Regulations Modify Information Reporting for Section 751(a) Partnership Interest Exchanges The Impermeable Reach of Section 6672: Joint and Several Trust...

  21. 2026-05-18 If a Client Claims Charitable Contributions You Must Understand the CWA Rules

    This week we look at: Technical Analysis of the Proposed Regulations Establishing Excepted Fertility Benefits Analysis of the IRS Time-Limited Settlement Initiative for Conservation Easement Disputes Strict Compliance with Contemporaneous Written Acknowledgment Requirements in Charitable Land...

  22. 2026-05-11 The Expensive Lost White Receipt and Certified Mailing

    This week we look at: Syndicated Conservation Easements and the Valuation Conundrum: An Analysis of T.C. Memo. 2026-36 Analysis of Garcia-Rojas v. Franchise Tax Board: The Limits of the Unitary Business Doctrine for Sole Proprietors An Analysis of the Reinstated Significant Issue Letter Ruling...

  23. 2026-05-04 Treasury Previews Upcoming 280E Medical Marijuana Guidance

    This week we look at: Reasonable Cause Relief Under the Small-Corporation Provision for Form 5472 Penalties Extending the Statute of Limitations for Disallowed ERC Claims Legislative Update: House Passes Comprehensive Tax Administration and Relief Bills Anticipated IRS Guidance Following the...

  24. 2026-04-27 No More 280E for State-Legal Medical Cannabis Businesses

    This week we look at: Tax Implications of the Rescheduling of State-Licensed Medical Marijuana Disallowance of COVID-19 Leave Credits: A Review of Substantiation and Trade or Business Requirements The Tenth Circuit Codifies the Reach of the Economic Substance Doctrine Over Mechanical Statutory...

  25. 2026-04-20 Final Regulations Issued on Qualified Tip Income

    This week we look at: A Technical Analysis of the Final Section 224 Regulations on the Qualified Tip Deduction Analysis of Proposed Regulations on Information Reporting Thresholds and Wagering Losses (REG-113229-25) U.S. District Court Splits Its Ruling on Micro-Captive Disclosure Mandates IRS...

  26. 2026-03-23 Claim of Right and the Correct Tax Year

    This week we look at: Corporate Capacity and State Law Revivor Digital Asset Identification Relief Interest and Bonus Depreciation Relief ERC Disallowances and Legal Standing Substantiation Rules for Emergency Vehicles Partnership Audits and Due Process Social Security Repayments

  27. 2026-03-16 Trump Account Proposed Regulations

    This week we look at: Proposed Regulations for IRC Section 530A "Trump Accounts" IRC Section 6434 Trump Account Pilot Program Micro-Captive Scrutiny Formalized BBA Audits: Notice Defects and the Statute of Limitations

  28. 2026-03-09 Sir You Are About to Lose Your Passport

    This week we look at: Fiduciary and Beneficiary Liability for Unpaid Estate Taxes Retroactive Entity Classification and Partnership Basis 2026 Passenger Auto Depreciation Limits Passport Certification & Victimization Defenses Passport Revocation in Collection Suits Waiver of Foreign Earned Income...

  29. 2026-03-02 Another Circuit Find IRS Has Assessment Authority for Section 6038(b) Penalties

    This week we look at: Required Minimum Distribution Regulations Delay CDP Proceedings and Underlying Liabilities Section 743(b) Adjustments and Economic Substance Assessability of Section 6038(b) Penalties

  30. 2026-02-23 Supreme Court Strikes Down Tariffs

    This week we look at: Supreme Court Invalidates Executive Tariffs Under IEEPA Special Depreciation Allowance Under the OBBBA CAMT Adjustments and Relief Circuit Split on Third-Party Fraud Valuation and Penalties in Syndicated Conservation Easements

  31. 2026-02-16 Hallucinations Enter the Tax Court

    This week we look at: TEFRA Jurisdiction and the "Limited Partner" Exception Artificial Intelligence and Substantiation Section 183 Profit Motive Rebate vs. Nonrebate Refunds Substantiation and Civil Fraud Consolidated Return Jurisdiction Copyright 2026, Thomas, Zollars & Lynch Ltd.

  32. 2026-02-09 Another Former Spouse Ends Up With a Jackpot When Her Ex-Spouse Dies Due to ERISA

    This week we look at: The "Charitable LLC" Tax Shelter Section 280E Bars ERC for Cannabis Businesses TEFRA Intervention by Majority Partners R&D Credit Substantiation Supervisory Approval of Penalties ERISA Beneficiary Designations

  33. 2026-02-02 Paper Refund Checks Notices and Patience Now

    This week we look at: Challenging the Presumption of Delivery (CDP Cases) Bank Deposits & Conduit Theory Mandates Under Executive Order 14247 (Notice CP53E) IRS Implementation of Executive Order 14247 - (FS 2026-02) Federal Priority Statute Liability FASIT Structure & Substantial Compliance

  34. 2026-01-26 Court Allows ERC Claim to Go Forward-But Throws Out APA Challenge

    This week we look at: ERC Refund Suits and Challenges to IRS Notice 2021-20 Section 6015(f) Equitable Relief and Attribution of Income Financial Disability Tolling under § 6511(h) Distinguishing "Tax Loss" for Sentencing vs. Restitution Implementation of Qualified Overtime Deductions (OBBBA)

  35. 2026-01-19 Fifth Circuit Reverses Tax Court on SE Income for State Law Limited Partners

    This week we look at: SE Tax Liability for Limited Partners (Sirius Solutions) Whistleblower Awards and "Collected Proceeds" Statutory Construction of Section 168(k) Amendments Updated Safe Harbor Explanations for Section 402(f) Modernized Group Tax Exemption Framework Tax-Exempt Status of...

  36. 2026-01-05 Proposed Regulations on New Car Loan Interest Deduction

    This week we look at: Standard Mileage Rates & Notice 2026-10 2026 Procedural Updates - Annual Revenue Procedures Qualified Passenger Vehicle Loan Interest (QPVLI) Proposed Regulations Estate of Spenlinhauer v. Commissioner Late Filing and More Bargain Sale of For-Profit colleges to a Non-Profit...

  37. 2025-12-29 Marijuana Rescheduling Restarts After Long Pause

    This week we look at: Executive Action on Marijuana Scheduling and IRC § 280E State Paid Family and Medical Leave (PFML) Programs Estimated Tax Relief for Qualified Farmland Sales IRC § 163(j) Interest Limitation Updates Premium Tax Credit (PTC) Revisions

  38. 2025-12-22 Initial Scholarship Granting Organization Guidance Issued

    This week we look at: Section 25F Advance Elections Unreported Income & The "Missing Witness" Constitutionality of Penalties Post-Jarkesy Section 280E & Offers-in-Compromise Substantiating Bad Debt & NOLs

  39. 2025-12-15 Postmark Date Risk Due to USPS Change

    This week we look at USPS Changes to Postmark Date System H.R. 1491: Disaster Related Extension of Deadlines Act Capitalization Priorities: Temnorod v. Commissioner Notice 2026-5: HSA Expansion Under OBBBA Fulfillment by Amazon (FBA) and "Doing Business" Substantiation Failures: Mirch v....

  40. 2025-12-08 Initial Details Released on Trump Accounts

    This week we look at: Notice 2025-68 – Implementation of Trump Accounts Draft Form 4547 – Elections and Filing Mechanics Notice 2025-70 – The OBBBA Scholarship Tax Credit Alioto v. Commissioner – Corporate Distinctness

  41. 2025-11-24 Tips and Overtime Form 1040 Reporting Reiief

    This week we look at: Innocent Spouse Relief Determination Standards Adjustments to Medicare Parts A, B, and D Equitable Distribution vs. Alimony (Pre-TCJA) Implementation of the Section 139L Interest Exclusion OBBBA Deductions for Tips and Overtime Compensation for 2025 returns

  42. 2025-11-15 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 Waivers

  43. 2025-11-10 Employer Guidance for 2025 Qualified Tips and Overtime

    This week we look at: Conservation Easement Valuation and Highest and Best Use Trust Fund Recovery Penalty (TFRP) Application California Residency and Taxpayer Burden of Proof OBBBA Information Reporting Transition Relief SCOTUS Oral Argument on IEEPA Tariffs Conservation Easement Timing and...

  44. 2025-11-03 Qualifying Offers in Tax Disputes

    This week we look at: Private Inurement and Operational Failure Prevailing Party Status Under § 7430 The Federal Priority Statute and Corporate Officer Liability Termination of the Automatic Stay in Bankruptcy Injunction Violations and Civil Contempt for Tax Preparer A Refined Approach to Math...

  45. 2025-10-27 More IRS Government Shutdown Clarifications

    This week we look at: Reevaluating the DC-QIE Exception (FIRPTA) Technical Revisions to Revenue Procedure 2025-32 Transitional Reporting for Qualified Passenger Vehicle Loan Interest (QPVLI) Jurisdictional Clarity for TEFRA Readjustment Petitions S Corporation Income Attribution and…

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  46. 2025-10-20 Who Owns a Hotel's ERTC Refund?

    This week we look at: Employee Retention Credit Refunds in Bankruptcy Lawsuit Settlement Enforcement and Tax Disclosure Obligations Operational Test Failure: Commercial Activities and Private Benefit IRS E-File Suspension Authority Taxation of International Investment Losses Collection Due…

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  47. 2025-10-13 2026 Tax Year Inflation Numbers Published

    This week we look at: Updated SIFL Rates for Noncommercial Employer-Provided Flights Supervisory Approval, Reasoned Decision Making, and the Limits of APA Review in Tax Court Tax Exemption Denial for a Gated Community HOA by the Tax Court Cancellation-of-Indebtedness Income Timing and the…

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  48. 2025-10-06 Guidance Push in Shutdown Week

    This week we look at IRS Updates PTIN User Fee Withdrawal of Corporate Reorganization Proposed Regulations IRS FY2026 Shutdown Contingency Plan Guidance on Rural Qualified Opportunity Zones New Interim Guidance on the Corporate AMT Tax Relief Extension for Terroristic Action in Israel Final...

  49. 2025-09-29 The End of Individual Refund Checks Approaches

    This week we look at: Hobby Loss Rules: Young v. Commissioner, T.C. Memo. 2025-95 Drought-Forced Livestock Sales: IRS Notice 2025-52 Per Diem Rates: IRS Notice 2025-54 End of Paper Refunds: IR-2025-94 / E.O. 14247 Syndicated Conservation Easements: Jackson Stone South, LLC v. Commissioner, T.C....

  50. 2025-09-22 Catch-Up Contribution SECURE 2.0 Regulations Released

    This week we look at: Final Regulations for Catch-Up Contributions (TD 10033) Draft Schedule 1-A (Form 1040) for 2025 Urgent Warnings of State Revenue Department Phishing Scams Tax Court Developments (Blomquist Holdings) Proposed Tax Administration Legislation New Deduction for Qualified Tips: An...

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Federal Tax Update Podcast Series

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