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 JurisdictionalBack 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 DeloreanTaxpayer Assistance and Service Act Title IV: Office of the Taxpayer Advocate
This is the fourth 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 IV: Office of the Taxpayer AdvocateThe Taxpayer Assistance and Service Act: Title III: Judicial Review
This article is the third 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 The Taxpayer Assistance and Service Act: Title III: Judicial ReviewThe Taxpayer Assistance and Service Act: Title II: American Citizens Abroad
This article is the second 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 The Taxpayer Assistance and Service Act: Title II: American Citizens AbroadIRS Commissioner’s Office Vacant Once Again
In the wake of a March 9 letter from three U.S. Senators expressing concerns about Treasury Secretary Scott Bessent’s dual role as Acting IRS Commissioner, the IRS announced today that
Continue Reading IRS Commissioner’s Office Vacant Once AgainGroup of U.S. Senators Sound Alarm About State of Federal Tax Enforcement
In the midst of Congressional consideration of the administration’s FY2026 budget request for the Internal Revenue Service (which was ultimately approved on February 3, 2026), a group of U.S. Senators
Continue Reading Group of U.S. Senators Sound Alarm About State of Federal Tax Enforcement