Taxpayers who make frivolous arguments in Tax Court risk the imposition of penalties by the court of up to $25,000.
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TOPICS
IRS Practice & Procedure
IRS releases Whistleblower Office operating plan
The plan’s promised enhancements include improving claims submittal and processing and communication with whistleblowers.
Late election relief in recent IRS letter rulings
The IRS may grant a reasonable extension if the taxpayer provides satisfactory evidence of acting reasonably and in good faith and the relief will not prejudice the government’s interests.
Digital asset transactions: Broker reporting, amount realized, and basis
Final regulations provide comprehensive guidance for tax reporting of transactions involving these increasingly common assets, and the IRS has granted transition relief in key areas.
Second Circuit: Sec. 6213(a) is nonjurisdictional; tolling applies
Second Circuit holds Sec. 6213(a) deadline is nonjurisdictional.
Preparer’s intent to evade tax extends taxpayer’s limitation period
‘Intent to evade tax’ can be the intent of a taxpayer’s tax return
preparer.
AICPA asks Treasury, IRS to change approach to dual consolidated losses
A letter urges an exception to the current “all or nothing” approach that prevents U.S. companies from deducting any part of a dual consolidated loss if even a portion of the DCL was used in a foreign country.
About 1 million taxpayers to get automatic penalty relief next year
During a session at the AICPA National Tax Conference, the national taxpayer advocate said the IRS will start applying first-time abatements automatically next year.
IRS clarifies how employees can claim 2025 tip and overtime deductions
The IRS also is updating some income tax forms and instructions to help taxpayers claim the deductions.
AICPA warns that merger of IRS offices would ‘confuse’ taxpayers
The proposed merger of the Office of Professional Responsibility and the Return Preparer Office would blur “the public’s ability to perceive the distinction between credentialed, uncredentialed, and unenrolled preparers,” the AICPA said in a letter.
Is the IRS just between shutdowns? Former IRS commissioners are worried
Three former IRS leaders, speaking at the 2025 AICPA National Tax Conference, discussed the agency’s future and what happens if a shutdown occurs during filing season.
Inflation adjustments to retirement account limits issued for 2026
The IRS announced inflation-adjusted limits on benefits and contributions for various retirement accounts on Thursday, including maximum contribution amounts for 401(k) plans and traditional and Roth IRAs.
Almost 1,400 IRS employees receive layoff notices, adding to staff losses
In court documents filed in a lawsuit, officials said 1,446 Treasury employees received reduction-in-force notices, including 1,399 at the IRS.
IRS ends Direct File, shifts focus to Free File upgrades and private sector
The IRS cited low usage and high costs as reasons for shuttering the program, which began during the previous administration.
Employers get reporting relief on tips, overtime; won’t face penalties for tax year 2025
An IRS notice says employers won’t face penalties if they don’t provide a separate accounting of cash tips and overtime compensation for tax year 2025 under H.R. 1.
Equitable tolling does not apply to excuse late filing of petition
On remand from the Eighth Circuit and after the Supreme Court held in the case that the Sec. 6330(d)(1) period for filing a Tax Court petition for a review of a Collection Due Process determination is nonjurisdictional, the Tax Court denied equitable tolling of the deadline.
Final partnership adjustment not issued timely
The Tax Court found a regulation invalid to the extent it holds the period open for the IRS to issue a final partnership adjustment longer than the statutory 270 days after a partnership has submitted “everything required” for a complete modification request.
Estate of McKelvey highlights potential tax pitfalls of variable prepaid forward contracts
A taxpayer’s extension of variable prepaid forward contracts resulted in a constructive sale and a termination of obligations that gave rise to taxable gain, the Tax Court held.
IRS renews corporate tax opportunities with letter rulings
After decades of limiting private letter ruling issues, the IRS has steadily widened its program, providing taxpayers greater certainty.
Congress passes bill requiring IRS to clarify math error notices
The AICPA praised the Senate passage of the bill, saying it will enhance IRS operations and improve the taxpayer experience.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
