Federal Tax Update Podcast

This week we look at: Tax Implications of the Rescheduling of State-Licensed Medical Marijuana Disallowance of COVID-19 Leave Credits: A Review of Substantiation and Trade or Business Requirements The Tenth Circuit Codifies the Reach of the Economic Substance Doctrine Over Mechanical Statutory Compliance Substantiation, Entity Indebtedness, and Business Expense Deductibility: An Analysis of the Simmons Case Treatment of Loyalty Rewards Program Funds and the Claim of Right Doctrine Valuation and Penalty Controversies in Estate Tax Examinations

This week we look at: A Technical Analysis of the Final Section 224 Regulations on the Qualified Tip Deduction Analysis of Proposed Regulations on Information Reporting Thresholds and Wagering Losses (REG-113229-25) U.S. District Court Splits Its Ruling on Micro-Captive Disclosure Mandates IRS Reduces Enrolled Agent Special Enrollment Examination User Fees: An Analysis of the Interim Final and Proposed Regulations Taxation of Terminated Life Insurance Policies: An Analysis of Constructive Receipt and Investment Interest  

This week we look at: Corporate Capacity and State Law Revivor Digital Asset Identification Relief Interest and Bonus Depreciation Relief ERC Disallowances and Legal Standing Substantiation Rules for Emergency Vehicles Partnership Audits and Due Process Social Security Repayments  

This week we look at: Proposed Regulations for IRC Section 530A "Trump Accounts" IRC Section 6434 Trump Account Pilot Program Micro-Captive Scrutiny Formalized BBA Audits: Notice Defects and the Statute of Limitations

This week we look at: Fiduciary and Beneficiary Liability for Unpaid Estate Taxes Retroactive Entity Classification and Partnership Basis 2026 Passenger Auto Depreciation Limits Passport Certification & Victimization Defenses Passport Revocation in Collection Suits Waiver of Foreign Earned Income Exclusion Time Rules New Digital Asset Reporting Landscape (Form 1099-DA)

This week we look at: Required Minimum Distribution Regulations Delay CDP Proceedings and Underlying Liabilities Section 743(b) Adjustments and Economic Substance Assessability of Section 6038(b) Penalties

This week we look at: Supreme Court Invalidates Executive Tariffs Under IEEPA  Special Depreciation Allowance Under the OBBBA  CAMT Adjustments and Relief  Circuit Split on Third-Party Fraud  Valuation and Penalties in Syndicated Conservation Easements

This week we look at: TEFRA Jurisdiction and the "Limited Partner" Exception Artificial Intelligence and Substantiation Section 183 Profit Motive Rebate vs. Nonrebate Refunds Substantiation and Civil Fraud Consolidated Return Jurisdiction Copyright 2026, Thomas, Zollars & Lynch Ltd.

This week we look at: The "Charitable LLC" Tax Shelter Section 280E Bars ERC for Cannabis Businesses TEFRA Intervention by Majority Partners R&D Credit Substantiation Supervisory Approval of Penalties ERISA Beneficiary Designations

This week we look at: Challenging the Presumption of Delivery (CDP Cases) Bank Deposits & Conduit Theory Mandates Under Executive Order 14247 (Notice CP53E) IRS Implementation of Executive Order 14247 - (FS 2026-02) Federal Priority Statute Liability FASIT Structure & Substantial Compliance

This week we look at: ERC Refund Suits and Challenges to IRS Notice 2021-20 Section 6015(f) Equitable Relief and Attribution of Income Financial Disability Tolling under § 6511(h) Distinguishing "Tax Loss" for Sentencing vs. Restitution Implementation of Qualified Overtime Deductions (OBBBA)

This week we look at: SE Tax Liability for Limited Partners (Sirius Solutions) Whistleblower Awards and "Collected Proceeds" Statutory Construction of Section 168(k) Amendments Updated Safe Harbor Explanations for Section 402(f) Modernized Group Tax Exemption Framework Tax-Exempt Status of Supplemental Military Housing Allowances

This week we look at: Standard Mileage Rates & Notice 2026-10 2026 Procedural Updates - Annual Revenue Procedures Qualified Passenger Vehicle Loan Interest (QPVLI) Proposed Regulations Estate of Spenlinhauer v. Commissioner Late Filing and More Bargain Sale of For-Profit colleges to a Non-Profit (501(c)(3))

This week we look at: Executive Action on Marijuana Scheduling and IRC § 280E State Paid Family and Medical Leave (PFML) Programs Estimated Tax Relief for Qualified Farmland Sales IRC § 163(j) Interest Limitation Updates Premium Tax Credit (PTC) Revisions

This week we look at: Section 25F Advance Elections Unreported Income & The "Missing Witness" Constitutionality of Penalties Post-Jarkesy Section 280E & Offers-in-Compromise Substantiating Bad Debt & NOLs

This week we look at USPS Changes to Postmark Date System H.R. 1491: Disaster Related Extension of Deadlines Act Capitalization Priorities: Temnorod v. Commissioner Notice 2026-5: HSA Expansion Under OBBBA Fulfillment by Amazon (FBA) and "Doing Business" Substantiation Failures: Mirch v. Commissioner

This week we look at: Notice 2025-68 – Implementation of Trump Accounts Draft Form 4547 – Elections and Filing Mechanics Notice 2025-70 – The OBBBA Scholarship Tax Credit Alioto v. Commissioner – Corporate Distinctness

This week we look at: Innocent Spouse Relief Determination Standards Adjustments to Medicare Parts A, B, and D Equitable Distribution vs. Alimony (Pre-TCJA) Implementation of the Section 139L Interest Exclusion OBBBA Deductions for Tips and Overtime Compensation for 2025 returns

This week we look at: Annual Adjustments to Retirement Plan Limitations Ensuring Investment Trust Status for Digital Asset Staking Entities Examining Penalties in Microcaptive Transactions Ownership Requirements for Non-Business Theft Losses Defining the Scope of I.R.C. § 172(b)(3) Carryback Waivers

This week we look at: Conservation Easement Valuation and Highest and Best Use Trust Fund Recovery Penalty (TFRP) Application California Residency and Taxpayer Burden of Proof OBBBA Information Reporting Transition Relief SCOTUS Oral Argument on IEEPA Tariffs Conservation Easement Timing and Penalties Digital Asset Broker Reporting FAQ Guidance