The court held that the notice was not sent
to the taxpayer’s last known address.
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TOPICS / TAX
Individual income taxation
Fact sheet addresses taxability of crowdfunding distributions
The IRS said that crowdfunding distributions may be included in the gross income of the person receiving them, depending on the facts and circumstances of the distributions.
Third Circuit rules taxpayer’s claim is not moot
The IRS’s setoffs of tax prepayments were invalid, the appellate court holds, remanding the case to the Tax Court.
Second Circuit lacks jurisdiction in small tax case
Sec. 7463(b) forecloses a review of the Tax Court’s dismissal, the appellate court holds.
Criminally forfeited IRA distribution was constructively received and taxable
The Tax Court denies an incarcerated taxpayer’s arguments to the contrary.
Foreign trust transactions and large gifts addressed in proposed regs.
The proposed regulations implement Secs. 643(i), 679, 6039F, 6048, and 6677, which were added or modified to prevent efforts by U.S. taxpayers to use foreign trusts and offshore arrangements to avoid U.S. taxes.
IRS Appeals abused its discretion by abruptly ending CDP hearing
Rejection of the taxpayer’s proposed collection alternatives was ‘hasty,’ the Tax Court finds.
Excise tax imposed on $25 million in excess IRA contributions
The Tax Court rebuffs the taxpayer’s argument that the Sec. 4973 tax is actually a penalty.
Tax Court has jurisdiction to hear taxpayers’ case
A notice of deficiency’s petition filing deadline controls despite, in an ‘obvious mistake,’ being more than a year after the notice’s mailing date.
Two home energy rebates not includible in gross income, IRS says
The IRS said it will not include the rebates provided under the Inflation Reduction Act of 2022 in individual purchasers’ gross income or in the cost basis of the property purchased.
Court’s inaccessibility extends taxpayers’ petition filing deadline
Although mailed after the 90- day deadline had expired, the petition was timely because it was filed within a 14-day extension provided under Sec. 7451(b)(1).
Foreign earned income and housing exclusion denied
Another worker at a U.S.–Australia joint defense facility fails to nullify a closing agreement waiver.
Tax Court petition is ruled untimely
When a private delivery service is used, it must be one the IRS has specifically identified to satisfy Sec. 7502, the Tax Court holds.
What kind of deduction is a hobby expense?
In a case of first impression for the Eleventh Circuit, the court affirmed a Tax Court holding that expenses of activities not engaged in for profit, i.e., hobbies, are allowable only as miscellaneous itemized deductions under Sec. 67(a).
On Form 1099-K delays, Werfel says IRS must protect taxpayer rights
IRS Commissioner Danny Werfel also discussed the employee retention credit and IRS funding when he appeared before the House Ways and Means Committee on Thursday.
Auto depreciation limitations increase
The IRS issued the 2024 depreciation limitations for passenger automobiles, including those for which bonus depreciation is applied.
House OKs $78B tax bill with changes to ERC and child tax credits
The bill, which now goes to the Senate, also delays amortization of research or experimental costs and restores tax breaks for companies from 2017’s Tax Cuts and Jobs Act.
Interest from past-due child support is includible in income
The Tax Court denied a taxpayer’s contention that the payments were excludable as child support.
Taxpayer lacks reasonable cause for CPA’s failure to e-file his returns
The Eleventh Circuit held that Boyle applies to e-filed returns.
Don’t wait on action on tax bill to file returns, IRS tells taxpayers
With tax season opened as of Monday, Commissioner Danny Werfel said the IRS will handle any necessary changes if a bill passes after returns are filed.
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