Editor: Lorin D. Luchs, CPA, J.D., LL.M. On June 16, 2008, the IRS issued proposed regulations (REG-129243-07) on tax return preparer penalty standards that it hopes to have finalized by the end of the year. The proposed regulations amend existing regulations to take into account the provisions in the Small
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IRS Practice & Procedure
An Analysis of the New Preparer Penalty Proposed Regulations
This article analyzes the proposed regulations on the new Sec. 6694 preparer penalty provisions that were enacted as part of the Small Business and Work Opportunity Tax Act of 2007.
AICPA Comments on Sec. 409A Correction Program
In Notice 2007-100, the Service established a correction program for certain failures to comply with Sec. 409A (governing nonqualified deferred compensation plans). The correction program provides for the self-correction of certain unintentional operational errors without any penalty if the error is corrected within the same tax year in which the
IRS Shortens Filing Extension Deadline for Some Entities
At the end of June, the IRS announced that it was changing the extended due date for certain returns from six months to five months (T.D. 9407; REG-115457-08). This was done to solve a problem some individual taxpayers have been having in which they receive timely Schedules K-1 on October
Tax Court Does Not Have Jurisdiction Over Duplicate Request for Relief
The Tax Court held that it lacked jurisdiction over a request for Sec. 6015(f) equitable relief that was based on the same facts and grounds for relief as an earlier request that had been denied by the IRS. Facts Judith Barnes was married to Nathan Genrich. On their joint return
Temp. Regs. Give Guidance on Return Preparer Information Disclosures
The Service released final and temporary regulations that govern the disclosure of a taxpayer’s Social Security number to overseas return preparers (T.D. 9409; REG-121698–08). Under the temporary regulations, such disclosure will be permitted in limited cases, with the taxpayer’s consent. Return preparers are generally forbidden to disclose a taxpayer’s Social
Taxation of Exchange Traded Notes
This item provides an overview of the structure of an exchange traded note and the current tax treatment of these instruments and an update on some of the guidance that has been issued related to taxation of ETNs
Sec. 6511 Limitation Applies to Excise Tax Refund
In a case of first impression, the Court of Federal Claims has held that Sec. 6511(a) limits Sec. 4251 telephone excise tax refund claims to two years after the tax was paid.
Farm Bill Enacted over President’s Veto
The Heartland, Habitat, Harvest, and Horticulture Act provides tax breaks for farmers, fuel credits, relief for parts of Kansas affected by storms in 2007, and a change in corporate estimated tax payments for 2012
Proposed Preparer Penalty Regs. Released
Proposed regulations implement changes to the return preparer penalties in Secs. 6694 and 6695 and related provisions.
The Importance of CPAs Supporting VITA: One CPA’s Experience
It is important that CPAs provide their expertise to ensure that VITA provides the level of required service and quality of return preparation.
IRS Enforcement Activities: Past, Present, and Future
This article reviews IRS enforcement activities since 1997 that relate to individual taxpayers.
Reportable Transactions: When Does the 90-Day Disclosure Rule Apply?
Failure to timely disclose a listed transaction or a transaction of interest could result in significant penalties—up to $200,000—even if there is no tax due. Because these rules can be confusing and mistakes are costly, knowing whether the 90-day time limit applies to a transaction is essential.
Forms 8275 and 8275-R: How Much Information Is Enough?
Adequate disclosure can protect the preparer and taxpayer from penalties in certain cases. However, preparing a disclosure that is adequate to apprise the IRS of the controversy without prejudicing the taxpayer is not a simple task.
Refund Claims and the Saturday-Sunday-Holiday Rule of Sec. 7503
In two revenue rulings issued almost 40 years apart, the IRS explored the effect of the Saturday-Sunday-holiday rule on the limitation periods applicable to refund claims.
Tax Court Reviews Only Final Supplemental Notice of Determination
The Tax Court held that where a collection due process challenge results in the issuance of one or more supplemental notices of determination, the Tax Court is required to review only the final supplemental determination.
Tax Court Vacates Stipulated Decisions in Tax Shelter Case
In the latest decision in one of its longest running series of cases, the Tax Court granted the motion of a group of taxpayers to vacate stipulated decisions in their cases that were part of the IRS’s Kersting tax shelter project.
IRS Provides Guidance on Return Preparer Penalties
The IRS has provided guidance (Notice 2008-46) on the implementation of the return preparer penalties under Sec. 6694.
AICPA Asks Court to Nullify Tax Patents
The AICPA has submitted an amicus brief in the patent case of In re Bilski, involving the patentability of business processes.
Sec. 1341 Roundup: Court Decisions and IRS Advice Offer Little Clarity
This item discusses four recent judicial decisions and administrative pronouncements addressing Sec. 1341.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
