Funding Your Living Trust: What You Need to Know
The Essential Blueprint for a Secure Future Imagine crafting a beautiful home, meticulously designing each room to reflect your personality and aspirations. Now, consider your living trust as that home—an essential structure where your assets reside, waiting to be...
Understanding the Taxpayer Advocate Service’s Community Partnerships
Unveiling the Hidden Gems of Taxpayer Support In a world where tax codes can feel like labyrinths designed to ensnare the unwary, the Taxpayer Advocate Service (TAS) stands as a beacon of hope for those lost in the shadows of IRS bureaucracy. This unique service not...
TEFRA Partnership not Entitled to Exclude Partners’ Distributive Shares from Self-Employment Income (Soroban Capital Partners LP, TCM)
A limited partnership classified as a TEFRA partnership was not entitled to exclude its limited partners’ distributive shares from net earnings from self-employment under Code Sec. 1402(a)(13). The Tax Court found that the individuals materially participated in the...
Tax Court Lacked Jurisdiction as IRS Failed to Establish Valid Notice of Deficiency (Cano, TCM)
The IRS failed to establish that it issued a valid notice of deficiency to an individual under Code Sec. 6212(b). Thus, the Tax Court dismissed the case due to lack of jurisdiction. The taxpayer filed a petition to seek re-determination of a deficiency for the tax...
Additional Transition Relief Provided for Brokers Required to File Form 1099-DA (Notice-2025-33; IR-2025-67)
The Treasury Department and IRS have issued Notice 2025-33, extending and modifying transition relief for brokers required to report digital asset transactions using Form 1099-DA, Digital Asset Proceeds From Broker Transactions. The notice builds upon the temporary...
Change of Accounting Method Procedures Updated (Rev. Proc. 2025-23)
The IRS has released guidance listing the specific changes in accounting method to which the automatic change procedures set forth in Rev. Proc. 2015-13, I.R.B. 2015- 5, 419, apply. The latest guidance updates and supersedes the current list of automatic changes found...
IRS Collects More Than $5 Trillion In 2024 (IR 2025-63)
The Internal Revenue Service collected more than $5.1 trillion in gross receipts in fiscal year 2024. It is the first time the agency broke the $5 trillion mark, according to the 2024 Data Book, an annual publication that reviews IRS activities for the given fiscal...
Supreme Court Rules Tax Court Lacks Jurisdiction Where IRS Withdraws Levy (Commissioner v. Zuch, SCt.)
The U.S. Tax Court lacks jurisdiction over a taxpayer’s appeal of a levy in a collection due process hearing when the IRS abandoned its levy because it applied the taxpayer’s later year overpayments to her earlier tax liability, eliminating the underpayment on which...