Reversing the Third Circuit, the Court holds that the Tax Court lacked jurisdiction over a collection due process appeal of a levy once the taxpayer’s underlying tax liability was satisfied and the IRS removed the levy.
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TOPICS / TAX
Individual income taxation
IRS did not concede taxpayer’s self-employment tax liability
A Social Security Administration letter advising of a reduction of his self-employment earnings record and an IRS refund were not concessions of liability for self-employment tax.
Reconciliation bill clears committee on second try
Sunday revote came after Republican fiscal hawks initially joined Democrats to sink the bill, which includes tax provisions approved by the House Ways and Means Committee last week.
Ways and Means approves proposed TCJA extensions and tax changes
The bill would make key portions of the TCJA permanent and create a new “senior bonus” deduction, among its many provisions. An AICPA statement said it is “deeply troubled” by the plan to curtail use of passthroughs to avoid SALT cap. The bill now heads to the House Budget Committee.
HSA inflation-adjusted maximum contribution amounts for 2026 announced
Rev. Proc. 2025-19 also includes the revised maximum amount that may be made newly available for excepted-benefit health reimbursement arrangements.
The home sale gain exclusion in today’s market
With the recent surge in home prices, it’s time for advisers to brush up on this valuable tax exclusion.
Tax Court petition deadline not tolled by identity theft claim
Equitable tolling did not apply in the taxpayers’ case because they failed to establish that the identity theft had prevented them from timely filing their Tax Court petition.
Deduction for theft loss and legal fees denied
The taxpayer failed to substantiate that a theft occurred or, if it did, its tax year of discovery for his investments in an alleged Ponzi scheme.
Taxpayer’s frivolous argument is once again denied
The Tax Court imposes a $25,000 frivolous-position penalty for persistent omission of wage and rental income.
Higher threshold for Form 1099-K reporting among AICPA priorities
In a letter to congressional finance leaders, the AICPA listed increasing the threshold to $10,000 as one of its priorities.
Frozen digital asset rewards constitute gross income
Digital asset rewards from staking and other activities constitute income in the year of receipt, irrespective of whether the account is later frozen, the IRS Chief Counsel’s office determined.
Lower auto depreciation limits issued for first time in at least 3 years
The IRS issued the 2025 depreciation limitations for passenger vehicles, including those for which bonus depreciation is applied.
Frivolous-tax-return penalty sustained
The Tax Court found all requirements of Sec. 6702(a) were met regarding the taxpayer’s zero-wage and -income return.
FBAR penalties are not extinguished upon taxpayer’s death
FBAR penalties accrue on the date the FBAR form is due, not the date the penalty is assessed, a district court held.
Final regs address taxes on gifts to taxpayers from ex-U.S. citizens, residents
The final regulations implement Sec. 2801, added to the Code in 2008, and follow up on proposed regulations issued 10 years ago.
Alternative methods allowed for identification of digital assets
The IRS provided temporary relief that permits eligible taxpayers to use alternative methods to make adequate identification of digital asset units sold, disposed of, or transferred in 2025.
Business standard mileage rate increases for 2025
The IRS increased the optional standard mileage rate used to calculate the deductible costs of operating a vehicle for business to 70 cents per mile driven, up 3 cents from 2024.
Applicability date set for required minimum distribution regulations
Treasury and the IRS announced that certain portions of future regulations finalizing the proposed regulations for required minimum distributions will apply beginning in the 2026 distribution calendar year.
IRS amends rules for computing the premium tax credit
The IRS released final regulations that amend the definition of “coverage month” and amend other rules in existing income tax regulations for computing the premium tax credit.
Writing and research activities not engaged in for profit
The Tax Court disallows a taxpayer’s claimed expense deductions.
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