Individual income taxation

TOPICS / TAX

August 1, 2024

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.

July 1, 2024

Second Circuit lacks jurisdiction in small tax case

Sec. 7463(b) forecloses a review of the Tax Court’s dismissal, the appellate court holds.

June 1, 2024

Criminally forfeited IRA distribution was constructively received and taxable

The Tax Court denies an incarcerated taxpayer’s arguments to the contrary.

May 8, 2024

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.

May 1, 2024

IRS Appeals abused its discretion by abruptly ending CDP hearing

Rejection of the taxpayer’s proposed collection alternatives was ‘hasty,’ the Tax Court finds.

May 1, 2024

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.

May 1, 2024

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.

April 8, 2024

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.

April 1, 2024

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).

April 1, 2024

Foreign earned income and housing exclusion denied

Another worker at a U.S.–Australia joint defense facility fails to nullify a closing agreement waiver.

April 1, 2024

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.

March 1, 2024

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).

February 16, 2024

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.

February 7, 2024

Auto depreciation limitations increase

The IRS issued the 2024 depreciation limitations for passenger automobiles, including those for which bonus depreciation is applied.

February 1, 2024

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.

February 1, 2024

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.

February 1, 2024

Taxpayer lacks reasonable cause for CPA’s failure to e-file his returns

The Eleventh Circuit held that Boyle applies to e-filed returns.

January 29, 2024

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.

January 1, 2024

IRS’s referral to DOJ did not bar collection proceedings

The taxpayers’ pending installment plan proposal did not prevent the referral, the Second Circuit affirms.

January 1, 2024

Tax Court petition held untimely

The taxpayers’ foreign travel did not entitle them to a 150-day extended deadline, the Tax Court held.

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