A TIGTA report found that IRS delays in resolving identity theft cases cost the government $124.2 million in refund interest from fiscal years 2023 through 2025. The findings echo warnings from National Taxpayer Advocate Erin Collins, who has called the wait times “unconscionable.”
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IRS Practice & Procedure
IRS finalizes increase in estate tax closing letter fee
The IRS issued final regulations increasing the cost of an estate tax closing letter to $76 from $56, adopting without change proposed regulations issued in June.
IRS raises per diem rates for business travel effective Oct. 1
In its annual update, the IRS increased the special per diem rates taxpayers may use to substantiate business travel expenses for the upcoming travel year and updated its list of high-cost localities.
AICPA, former IRS commissioner to lead initiative on AI in tax
Participants in the Council on AI Risk in Tax, led by the AICPA and former IRS commissioner Danny Werfel, include leaders from all areas of the tax world who will work together to promote the responsible use of AI in tax administration and practice.
IRS cyber weaknesses put taxpayer data at risk again, TIGTA says
For the second consecutive year, a government watchdog found the IRS’s cybersecurity program ineffective. TIGTA warned that taxpayer data could be vulnerable if security weaknesses are not addressed.
Unclear instructions, limited awareness plagued CP53E rollout, TIGTA says
Many CPAs and their clients experienced confusion over IRS CP53E notices during the 2026 filing season. A TIGTA report confirms those concerns and sheds new light on how the IRS implemented its paperless-payment initiative.
Government says Kwong court misread COVID tax relief law
In its opening brief to a federal appeals court Wednesday, the federal government said a lower court ruling in Kwong improperly turned a 60-day extension into a postponement period lasting over three years.
IRS delayed action on thousands of high-income nonfiler cases, TIGTA says
A TIGTA report found that nearly 39,000 high-priority nonfiler cases were delayed in the IRS’s high-income nonfiler initiative because of resource concerns. The IRS said it has since advanced all affected cases.
AICPA seeks IRS clarity on AI guidelines, CPA fees
The AICPA is seeking clarification from the IRS on guidelines suggesting that tax practitioners should pass AI-related cost savings on to clients. Concerns about language in the guidelines include the implication of not allowing for a value-pricing model and overlooking the costs of implementing and governing the technology.
Congress approves funding bill that maintains IRS budget
A stopgap funding bill headed to the president would maintain the IRS’s $11.2 billion annual budget through Dec. 11 and prevent a second $11.6 billion funding rescission for now.
A risk framework for AI use in tax administration and preparation
A former IRS commissioner assesses risks and proposes control practices for use of artificial intelligence by taxing authorities and practitioners.
Rev. Proc. 2026-17: Withdrawal of Sec. 163(j)(7) elections
Businesses should review interest limitation elections filed with 2022–2024 returns. Under the revenue procedure, certain taxpayers can withdraw past elections, potentially changing interest and depreciation treatment.
Tax legislation for digital assets: What’s the conversation in Congress?
Despite common themes between a Senate bill and a House discussion draft on taxation of digital assets, they differ in key areas.
Tax return positions: Required levels of authority
Tax practitioners must heed rules and professional guidelines for substantial authority and other specified levels of confidence in a tax position’s success upon being challenged on its merits.
Circuit courts split on home-distilling ban
While the Sixth Circuit held that the ban is necessary and proper under the U.S. Constitution for collecting a federal excise tax on spirits, the Fifth Circuit held under the same criterion that the ban is unconstitutional.
Erroneous refund of underpayment interest eligible for Sec. 6015(f)(1) relief
The refund gave rise to an unpaid tax liability eligible for equitable innocent-spouse relief, the Tax Court held.
IRS enforcement activity fell despite record tax collections, TIGTA says
Individual audit starts fell 30% in fiscal 2025, including a 27% drop among taxpayers with income above $400,000, as IRS staffing levels declined, TIGTA said.
IRS should automate name, address changes, AICPA says
A letter to the IRS says that processing times of six to eight weeks or longer for taxpayer name and address changes can create compliance risks and should be reduced through automation.
Taxpayers can now access IRS compliance report online
A new IRS Individual Online Account feature lets taxpayers download a digitally authenticated compliance report for use when applying for jobs, loans, government benefits, and other services.
Proposed rules would restrict Trump account eligible investments
The IRS proposed regulations that would limit Trump account investments to low-fee stock index funds and ETFs during the growth period.
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.
