The court granted the IRS’s motion because the petition was untimely and denied the taxpayer’s contending that the Service’s deficiency notices were invalid.
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TOPICS
IRS Practice & Procedure
Scope of review in passport cases is de novo
The Tax Court held that its review of a certification of a seriously delinquent tax debt potentially denying or revoking a taxpayer’s passport could include evidence introduced at trial.
Practical considerations for taxpayers and advisers following Loper Bright and Corner Post
Taxpayers and advisers should reckon with the two Supreme Court decisions when evaluating tax return positions that may conflict with existing administrative guidance.
Results of recent academic research may aid practitioner planning
Five tax research articles published in the past year in academic journals provide potentially valuable insights for practitioners.
Draft 2026 Form W-2 includes boxes and codes for tips and overtime
The IRS said previously that it will not release a new form for 2025, even though the temporary H.R. 1 provisions are effective this year, but it will provide transition relief.
IRS seeks to fill ‘critical vacancies’ as workforce declines 25%
The IRS has asked some employees who accepted deferred resignation offers if they want to stay on the job.
Will budget, staff cuts impede IRS modernization? Former commissioner weighs in
Former IRS Commissioner Danny Werfel says the cuts, combined with the need to reengineer systems for the OBBBA, will make it difficult for the IRS to succeed at improving technology.
IRS should be more transparent when communicating phone service metrics, report says
The report by the Treasury Inspector General for Tax Administration called on the IRS to include more phone lines and to cover the entire fiscal year when reporting on its level of service and wait times.
Prop. regs. would modify reporting obligations for Form 8308, Part IV
The IRS issued proposed regulations that would modify partnerships’ reporting obligations for Part IV of Form 8308 with respect to sales or exchanges of certain interests in partnerships owning inventory or unrealized receivables.
IRS clarifies that Appeals case memos should be shared with taxpayers upon request
National Taxpayer Advocate Erin Collins wrote Tuesday in her blog that the IRS reminder of the language in the Internal Revenue Manual is a “meaningful step toward transparency.”
Billy Long out as IRS commissioner after less than two months
Long said Friday on X that he’s leaving the IRS and instead will be nominated to be ambassador to Iceland.
No 2025 information return or withholding table changes under OBBBA
The IRS announced Thursday that it is delaying changes to certain information returns, withholding tables, and reporting and withholding procedures until tax year 2026 “to avoid disruptions.”
AICPA presses IRS for guidance on domestic research costs in OBBBA
In its letter, the AICPA said small businesses that have not filed returns for the 2024 filing period face uncertainty about how to treat domestic research and experimental expenditures.
Date to start filing season not set despite IRS commissioner’s comment
Commissioner Billy Long said last week that the next filing season would start around Presidents Day, but the IRS said Tuesday that it has not set a date.
IRS includes several AICPA recommendations in corporate AMT interim guidance
In a notice issued Tuesday, the IRS said it intends to partially withdraw proposed regulations and issue revised proposed regulations.
‘Garden variety’ mistake does not give rise to equitable tolling
Although the deadline for filing a challenge to an IRS employment status determination is nonjurisdictional, an employer’s facts did not warrant equitable tolling, the Tax Court held.
No proceeds from sale of husband’s home to pay tax debts go to wife
A state marital homestead law was insufficient to establish a property interest by a taxpayer whose husband was the home’s sole owner.
5 things to know about tax relief for federal disasters
While the IRS has discretion to provide relief, Sec. 7508A(d) provides a mandatory tax deadline postponement. In either case, the ‘lookback’ limitation period for refunds remains a concern.
Amended returns and the Sec. 965(k) six-year period for assessment
A Joint Committee on Taxation report’s language raises questions about the running of the statute of limitation for liability for the Sec. 965 transition tax.
New commissioner confident IRS can implement OBBBA’s tax provisions
Commissioner Billy Long explained his management philosophy at the 2025 Tax Summit of the National Association of Enrolled Agents, where he said IRS employees will be able to implement the OBBBA’s tax provisions.
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.
