Newsletters

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 the levy was based. The 8-1 ruling by the Court resolves a split between the Third Circuit and the Fourth and D.C. Circuit.


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 year.


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 in Rev. Proc. 2024-23, I.R.B. 2024-23.


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 relief previously provided in Notice 2024-56 and allows additional time for brokers to comply with reporting requirements.


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.


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 partnership’s investment management business and were not acting as limited partners “as such.”


Tax Alerts
Tax Briefing(s)
IRS Reminds Newlyweds To Update Tax Information for Smoother Filing
The IRS has advised newly married individuals to review and update their tax information to avoid delays and complications when filing their 2025 income tax returns. Since an individual’s filing sta...
IRS Offers Relief for Individuals Who Missed April Tax Filing Deadline (IR-2025-66)
The IRS has announced several online resources and flexible options for individuals who have not yet filed their federal income tax return for the tax year at issue. Those who owe taxes have been enco...
Court Lacked Jurisdiction to Rule on Innocent Spouse Relief (Fakir, DC Mich.)
A district court lacked jurisdiction to rule on an individual’s innocent spouse relief under Code Sec. 6015(d)(3), in the first instance. The individual and her husband, as taxpayers, were liable f...
LLC Not Entitled to Full Conservation Easement Deduction; Adjusted Basis Limitation Affirmed (Glade Creek Partners, LLC, CA-11)
A limited liability company classified as a TEFRA partnership was not entitled to deduct the full fair market value of a conservation easement under Code Sec. 170. The Court of Appeals affirmed the T...
Married Couple not Entitled to Refund for Depreciation Deduction (Shleifer, DC Fla.)
A married couple was not entitled to a tax refund based on a depreciation deduction for a private jet. The Court found the taxpayers’ amended return failed to state the correct legal basis for the c...
NJ - Clarification regarding graduated fee issued
New Jersey has provided clarification regarding the imposition of the Graduated Percent Fee on property deed transactions exceeding $1 million and shifting payment liability from grantees to grantors....
NY - Tax-exempt cigarette annual amounts for Indian nations or tribes announced
The New York Department of Taxation and Finance has determined the annual amount of stamped cigarette tax-exempt packs of cigarettes for each of the Indian nations or tribes for the period beginning S...
PA - Real estate valuation factors updated
Pennsylvania has released the real estate valuation factors applicable for documents accepted from July 1, 2025 through June 30, 2026. The factors are the mathematical reciprocals of the common level ...
IRS Reminds Newlyweds To Update Tax Information for Smoother Filing
The IRS has advised newly married individuals to review and update their tax information to avoid delays and complications when filing their 2025 income tax returns. Since an individual’s filing sta...
IRS Offers Relief for Individuals Who Missed April Tax Filing Deadline (IR-2025-66)
The IRS has announced several online resources and flexible options for individuals who have not yet filed their federal income tax return for the tax year at issue. Those who owe taxes have been enco...
Court Lacked Jurisdiction to Rule on Innocent Spouse Relief (Fakir, DC Mich.)
A district court lacked jurisdiction to rule on an individual’s innocent spouse relief under Code Sec. 6015(d)(3), in the first instance. The individual and her husband, as taxpayers, were liable f...
LLC Not Entitled to Full Conservation Easement Deduction; Adjusted Basis Limitation Affirmed (Glade Creek Partners, LLC, CA-11)
A limited liability company classified as a TEFRA partnership was not entitled to deduct the full fair market value of a conservation easement under Code Sec. 170. The Court of Appeals affirmed the T...
Married Couple not Entitled to Refund for Depreciation Deduction (Shleifer, DC Fla.)
A married couple was not entitled to a tax refund based on a depreciation deduction for a private jet. The Court found the taxpayers’ amended return failed to state the correct legal basis for the c...
NJ - Clarification regarding graduated fee issued
New Jersey has provided clarification regarding the imposition of the Graduated Percent Fee on property deed transactions exceeding $1 million and shifting payment liability from grantees to grantors....
NY - Tax-exempt cigarette annual amounts for Indian nations or tribes announced
The New York Department of Taxation and Finance has determined the annual amount of stamped cigarette tax-exempt packs of cigarettes for each of the Indian nations or tribes for the period beginning S...
PA - Real estate valuation factors updated
Pennsylvania has released the real estate valuation factors applicable for documents accepted from July 1, 2025 through June 30, 2026. The factors are the mathematical reciprocals of the common level ...