Current Federal Tax Developments

Hosted by Edward Zollars, CPA

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100

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Sep 2026

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Weekly update on federal income tax developments

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October 3, 2026

2026-10-05 Trump Accounts Established for All Children

This week we look at: Informal claim and COVID-19 disaster relief save an untimely-looking IRA refund suit in Singh. IRS recasts “Section 351 conversion” ETF transactions as taxable exchanges in Rev. Rul. 2026-20. Proposed regs implement a four-year installment election for farmland sales to young farmers. A corporate Offer-in-Compromise caps an officer's Trust Fund Recovery Penalty liability in Amodio. Treasury completes automatic enrollment in Trump Accounts under new Section 530A regulations. Sevillo Fine Foods: three independent grounds doom an ERC claim based on port congestion delays. Tax Court holds Form 872-T cannot terminate a fixed-date Form 872 extension in Fine v. Commissioner New IRS notice extends tax deadlines to September 2027 for Israel conflict-affected taxpayers Congress sends the National Taxpayer Advocate independent legal counsel in H.R. 997. New regulations build the infrastructure for the $1,700 Section 25F scholarship tax credit. An audio only version of this week’s podcast can be streamed or downloaded below: 2026-10-05 Trump Accounts Established for All Children Edward K. Zollars, CPA (Arizona) Download Articles for this week’s topics can be downloaded as a PDF below. 2026-10-05 Current Federal Tax Developments

September 26, 2026

2026-09-28 Estate Closing Letter Fee Increase Finalized

This week we look at: Tax Court Applies Equitable Tolling to BBA Partnership Petition Deadlines -- Kings Road Property District Court Voids VIBIR's Net Investment Income Tax Assessment -- Perkins IRS Notice 2026-55 Seeks Comments on Opportunity Zone Rules for Housing Developers Hurricane Michael Casualty and Charitable Deductions Fail for Lack of Substantiation -- Williams Treasury Raises the Estate Tax Closing Letter User Fee to $76 -- TD 10055 Tax Court Finds Proper Mailing Despite a Defective Form 3877 -- Lindsey Unsubstantiated Insider Loan Triggers 225-Percent Excise Tax Exposure -- Jagannath An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-09-28 Estate Closing Letter Fee Increase Finalized Edward K. Zollars, CPA (Arizona) Download Articles with this week’s developments can be downloaded below. Current Federal Tax Developments - September 28, 2026

September 19, 2026

2026-09-21 Tax Break for Preschool Teachers in the Russia Sanctions Bill

This week we look at: Tax Court Warns of AI Drafting Pitfalls in a CDP Lien Withdrawal Case -- Moore Altering the Perjury Jurat Dooms a Refund Suit -- Johnson v. IRS IRS Extends the Involuntary Conversion Period for Drought-Hit Livestock Sales H.R. 9500 Would Restore and Expand Personal Casualty and Theft Loss Relief Second Circuit Rejects Form Over Function for SECA Tax -- Soroban Capital Partners H.R. 5334 Expands the Educator Expense Deduction to Early Childhood Teachers An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-09-21 Tax Break for Preschool Teachers in the Russia Sanctions Bill Edward K. Zollars, CPA (Arizona) Download A copy of this week’s stories can be downloaded as a PDF below: 2026-09-21 Current Federal Tax Developments

September 12, 2026

2026-09-14 The Picasso and the Income

This week we look at: Final Regulations Restore the Car Loan Interest Deduction Under T.D. 10054 Fourth Circuit Affirms $2.9M Willful FBAR Penalty -- United States v. Rund Tax Court Clarifies BBA Extension Mechanics -- Katanga Properties Treasury Proposes Sweeping QOF Certification and Reporting Regulations Proposed Regs Allocate Foreign Source Deductions Under Sections 250 and 904 Unrestricted $16.5M Art Deal Funds Are Taxable Income -- Tunkl v. Commissioner An audio verision of this week’s broadcast can be streamed or downloaded below: 2026-09-14 The Picasso and the Income Edward K. Zollars, CPA Download You can download a PDF of this week’s articles at below: 2026-09-14 Current Federal Tax Developments

September 7, 2026

2026-09-07 IRS Bit By Not Mailing Via Certified Mail

This week we look at: Federal Circuit Bars Treaty FTCs Against the NIIT -- Bruyea and Christensen Financial Disability Tolling and Third-Party Authorization -- Goldman v. United States OIC Public-Policy Rejections Upheld -- Filipowski v. Commissioner Substantiation and Alter-Ego Doctrine -- Hank Risan v. Commissioner Codifying Racial Nondiscrimination for Private Schools -- Proposed Section 1.501(c)(3)-2 IRS's Certified-Mailing Burden of Proof -- Wales v. Commissioner Automatic Accounting Method Changes for R&E and Construction -- Rev. Proc. 2026-32 An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-09-07 IRS Bit by Not Mailing Via Certified Mail Edward K. Zollars, CPA (Arizona) Download Articles for this week’s update can be downloaded as a PDF below: 2026-09-07 Current Federal Tax Developments

August 31, 2026

2026-08-31 When is a Partnership Return Not a Return

This week we look at: Zero-Return Form 1065 Filings and the Beard Test (IRS CCA 202634014) Full Payment Rule & Presumption of Correctness -- Pellegrino v. United States Pro Rata Share Determinations Under OBBBA -- Proposed Regulations (REG-115646-25) Treaty Exclusivity for Pooled Investments -- South Saskatchewan Community Foundation v. U.S. An audio only version of this week’s broadcast can be streamed or downloaded below. 2026-08-31 When is a Partnership Return Not a Return Edward K. Zollars, CPA (Arizona) Download A PDF of articles for this week’s broadcast can be downloaded below: 2026-08-31 Current Federal Tax Developments

August 23, 2026

2026-08-24 Proposed Regulations Week

This week we look at: Form 1041-A Relief for Passthrough Charitable Deductions (REG-109082-25) Vested Development Rights & Easement Valuation — Malibu Valley Land v. Commissioner First Circuit Bars Equitable Tolling of Section 6213(a) — Kyick Holdings v. Commissioner PRWORA Immigration Restrictions on Refundable Credits (REG-119882-25) Single-Employer DB Pension Funding Proposed Regulations (REG-107855-25) Excluded Property Sales Income Under Section 250 (REG-117130-25) Section 163(j) Business Interest Limitation Update — Fact Sheet FS-2026-14 Doug LaMalfa Federal Disaster Tax Relief Certainty Act (H.R. 5366) IRS Ends Uniform Easement Settlement Initiative, Creates Office of Conservation Easements Trump Account Eligible Investment Rules — Proposed Regulations (RIN 1545-BS14) An audio only version of this week’s update can be streamed or downloaded below: 2026-08-24 Proposed Regulations Week Edward K. Zollars, CPA (Arizona) Download This week’s update articles and broadcast slides can be downloaded below; 2026-08-24 Current Federal Tax Developments 2026-08-24 Slides

August 16, 2026

2026-08-17 Maybe State Law Limited Partner Isn't the Test for 1402(a)(13)

This week we look at: Unpacking the Saver’s Match: Technical Guidance and Operational Frameworks Under Notice 2026-48 Harmonizing Section 3406 Backup Withholding with Section 6050W De Minimis Reporting Thresholds The High Bar for Equitable Tolling in Tax Practice: The Eighth Circuit’s Final Ruling in Boechler, P.C. Employer Contributions to Trump Accounts and Nondiscrimination Rules under REG-101355-26 The Perpetual Burden of Carryover Substantiation: AMT Credits and Recordkeeping in Beacom v. Commissioner Equitable Tolling of Tax Court Filing Deadlines: Maniktala v. Commissioner (8th Cir.) Standardizing Retirement Plan Rollovers and Trustee-to-Trustee Transfers under SECURE 2.0: Notice 2026-49 Unmasking the $70 Million Dubai Fraud: Section 165 Theft Loss Deductions in Deutsch v. Commissioner Treasury Proposes Substantive Section 987 Relief for Controlled Foreign Corporations (REG-103844-26) Rehearing Reversal: The Fifth Circuit’s Management Test for the Limited Partner Exception (K Alain, L.L.L.P.) The Crucial Role of Highest and Best Use in Conservation Easement Valuations: Evans v. Commissioner 2026-08-17 Maybe State Law Limited Partner Isn't the Test for 1402(a)(13) Edward K. Zollars, CPA (Arizona) Download You can download PDFs with copies of this week’s articles and slides below: 2026-08-17 Slides 2026-08-17 CFTD Articles

August 9, 2026

2026-08-10 IRS Guidance on Qualifed Overtime for 2026-2028

This week we look at: Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4) Trustee-to-Trustee Transfers of Inherited IRAs Through an Estate: Technical Analysis of PLR 202631001 Federal Courts Lack APA Jurisdiction Over Foreign Gift Penalty Disputes: The Adequate Alternative Remedy Barrier Sourcing Executive Termination Payments: Analyzing the Bifurcated Sourcing of Severance and RSUs in the Appeal of Otting The Permanent Section 45S Paid Family and Medical Leave Credit: Analyzing the Statutory Wage Method Mechanics and the New Premium Method Under Notice 2026-28 The Tax Court Open Door: Why the BBA Partnership Petition Deadline Is Not Jurisdictional Commingled Funds, Unsubstantiated Deductions, and the Binding Form of Transactions: A Technical Tax Analysis of Reed v. Commissioner The Safe Harbor That Wasn’t: Deconstructing the Anti-Abuse Rule in SIH Partners LLLP v. Commissioner The Evolution of Qualified Overtime Compensation Deductions: Analyzing IRS Fact Sheet FS-2026-13 and Its Practical Implications An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-08-10 IRS Guidance on Qualified Overtime for 2026-2028 Edward K. Zollars, CPA (Arizona) Download This week’s articles can be downloaded below: 2026-08-10 Current Federal Tax Developments

August 2, 2026

2026-08-03 On Again Off Again On Again PLR

This week we look at: IRS Reinstates Tax Deferral on Variable Annuity Term Certain Options: Reconsideration and Reversal in PLR 202630002 Understanding the ERC Pleading Standard: Federal Claims Court Deferral in I Health and Life Insurance Services Predecessor Losses, the Lonely Parent Rule, and the Limits of Economic Reality: Analysis of HBM Holdings Co. v. Commissioner Double Books and Disguised Payees: Corporate Personal Expenses and the Civil Fraud Penalty in Prezioso v. Commissioner An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-08-03 On Again Off Again On Again PLR Edward K. Zollars, CPA (Arizona) Download The articles for this week’s update can be downloaded as a PDF below: Current Federal Tax Developments August 3, 2026