IRS Insights

March 2025

Here are the latest tax rulings in our March edition:

• Tax Court Grants Taxpayer’s Motion for Reconsider Post Loper
  • The Tax Court’s recent decision to grant a motion for reconsideration in a hobby-loss case highlights the significant impact of the Supreme Court’s Loper decision.

• Tax Court Finds Equitable Tolling Does Not Apply to Tax Overpayment Refund Statutes
  • In a recent decision, the Tax Court rejected a taxpayer’s attempt to expand the equitable tolling ruling in the Supreme Court case of Boechler.

• Tax Court Applies Functional Analysis to NESE Limited Partner Exception
  • Recently, the Tax Court considered whether taxpayers were limited partners for purposes of the net earnings from self-employment (NESE) limited partner exception.
• Final Regulations Providing Guidance on Appeals Resolution Process Finalized
  • The Treasury Department issued final regulations (T.D. 10030) providing guidance on the resolution of Federal tax controversies by the Independent Office of Appeals, including twenty-four exceptions to a taxpayer’s general right to go to Appeals.

• IRS Expands Alternative Dispute Resolution (ADR) Programs
  • In January 2025, the IRS announced test pilot programs with three changes to its existing ADR programs. The IRS said the changes are to help taxpayers resolve issues without litigation as effectively and efficiently as possible.

Archive

November 2024
Interest netting - the hunt for the definition of “same taxpayer”

September 2024
Supreme Court upholds section 965 tax in Moore v., United States

May 2024
Court Rules Wrong Form Doesn’t Start IRS’s SOL

March 2024
IRS indefinitely authorizes electronic signatures for select forms and documents

September 2023
Supreme Court to Hear Challenge to Section 965 transition tax

May 2023
Recent Tax Court decision holds Form 5471 penalties are not immediately assessable by the IRS

March 2023
IRS proposes regulations regarding taxpayer access to Appeals

November 2022
Failure-to-file penalties apply when certain forms are paper file

August 2022
Tax Court reiterates rule that each tax year stands on its own

June 2022
Taxpayer refund suit dismissed for inability to prove timely mailing of refund claim

February 2022
Ninth Circuit adopts primary purpose test for determining whether attorney-client privilege applies to dual-purpose communications

October 2021
The IRS issued Notice 2021-39, announcing transition relief for Schedules K-2 and K-3 filers for taxable years beginning in 2021

July 2021
In Crandall v. Commissioner of Internal Revenue, the Tax Court addressed a question about the scope and effect of a closing agreement signed between the taxpayers and the IRS

April 2021
Court holds that Section 6676 erroneous refund penalty does not apply in Exxon Mobil Corp. v. United States

January 2021
Nonresident USVI taxpayer “filing” under Section 6501(a)

November 2020
Federal Claims Court Rules on Failure to Meet Reasonable Cause in Payroll Tax Obligations

September 2020
IRS Request Comments on Revenue Procedure 94-59

July 2020
CCA Memo on Meaning of “Attributable To” in 6511(d)(2)

May 2020
IRS issues Rev. Proc. 2020-23 to allow BBA partnerships to utilize relief provisions provided in the CARES Act

March 2020
Tax Court Tentatively Disallows Conservation Easement Deduction Due to Omitted Required Basis Information