On September 28, 2026, Treasury and the IRS issued Revenue Ruling 2026-20 and Notice 2026-62. Together they address Section 351/ETF conversions, ETFs’ use of in-kind redemptions to avoid income
Continue Reading “I Declare Nonrecognition!” Why the IRS Says Certain Section 351/ETF Conversions Don’t Work That Way
Your U.S. Tax Court Case Just Got Closer to Home
New Trial Cities, Broader Access, and a Pilot of a Smarter Calendar
On September 8, 2026, Chief Judge Urda announced three significant changes to how the United States Tax Court
Continue Reading Your U.S. Tax Court Case Just Got Closer to HomeIRS Revenue Officers Will Be Knocking on Doors in Lancaster County This August – Here’s What You Need to Know
If you own a business or reside in Lancaster County, pay close attention: the IRS confirmed in a July 21, 2026 letter that 20 revenue officers will be conducting face-to-face
Continue Reading IRS Revenue Officers Will Be Knocking on Doors in Lancaster County This August – Here’s What You Need to KnowTax Court Holds BBA Partnership Petition Filing Deadline Is Not Jurisdictional
In Big Apple Tompkins Realty LLC v. Commissioner, the Tax Court addressed a question of first impression: whether I.R.C. § 6234(a)’s 90-day petition filing deadline for partnerships subject to
Continue Reading Tax Court Holds BBA Partnership Petition Filing Deadline Is Not JurisdictionalThe Growing Business of Sports: A Tax Playbook Review
Get your popcorn ready because there is nothing more exciting than the intersection of sports and tax! As a former Division II athlete, the current state of college sports and
Continue Reading The Growing Business of Sports: A Tax Playbook ReviewBack to the Future: Tax Edition — Correcting SSN/TIN Issues Before the IRS Repossesses the Delorean
Every January, businesses race to issue Forms W-2, 1099, and 1099-NEC, but a small typo in a Social Security Number (SSN) or Taxpayer Identification Number (TIN) can turn into a
Continue Reading Back to the Future: Tax Edition — Correcting SSN/TIN Issues Before the IRS Repossesses the DeloreanHorse Breeding and Training Expense Deductions? Tax Court Says Neigh
In a June 9 opinion, the Tax Court held that a married couple were not engaged in horse breeding and training activities for profit and sustained the IRS’s disallowance
Continue Reading Horse Breeding and Training Expense Deductions? Tax Court Says NeighTaxpayer Assistance and Service Act Title VII: Whistleblowers
This is the seventh in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced
Continue Reading Taxpayer Assistance and Service Act Title VII: WhistleblowersTaxpayer Assistance and Service Act Title VI: IRS Independent Office of Appeals
This is the sixth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced
Continue Reading Taxpayer Assistance and Service Act Title VI: IRS Independent Office of AppealsTaxpayer Assistance and Service Act Title V: Tax Return Preparers
This article is the fifth in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service
Continue Reading Taxpayer Assistance and Service Act Title V: Tax Return Preparers