IRS Chief Counsel

On September 4, 2026, the IRS and Treasury Department published proposed regulations (REG-119986-25) that would redefine the nondiscrimination standards every tax-exempt private school must meet under section 501(c)(3). If finalized…

Continue Reading IRS Proposes New Racial Nondiscrimination Rules for Tax-Exempt Private Schools: What Your School Needs to Know

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 Jurisdictional

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 Delorean

Classroom participation points may boost a child’s grade in history class, but merely raising your hand won’t get you far with the IRS.  The passive activity loss rules under I.R.C.

Continue Reading No Points for Participation: Passive Activity Rules and Loss Limitations

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 Review

The Internal Revenue Service continues to experience significant leadership transition during a period of ongoing internal upheaval and uncertainty.  The latest developments are the appointment of Kenneth Kies as the…

Continue Reading IRS Leadership Turmoil Continues With Appointment of Yet Another Acting Chief Counsel While Chief of Appeals Announces Retirement