The Tax Court holds the taxpayer substantially complied with adequate-disclosure requirements via returns and documents submitted with an OVDP offer.
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TOPICS / TAX
IRS practice & procedure
Businesses must e-file Form 8300 for $10,000+ cash payments in 2024
The new e-filing requirement, beginning in 2024, applies to businesses mandated to e-file certain other information returns, such as Forms 1099 series and Forms W-2.
Prevailing wage and apprenticeship requirements guidance issued
The IRS issued proposed regulations related to the increased tax credit or deduction amounts for clean energy facilities and projects if taxpayers satisfy certain prevailing wage and registered apprenticeship requirements.
Prop. regs. require brokers to report digital asset sales and exchanges
Long-awaited proposed regulations, part of a broader effort by Treasury to close the tax gap and address tax evasion risks posed by digital assets, require brokers to report sales and exchanges of digital assets by customers.
Tax pros give mixed reviews to wait times, service on PPS line
Wait times increased about the same time as the IRS ended program that thwarted line-jumping services, say tax practitioners, who also questioned the training of new hires.
Guidance provided for electronic filing exemptions and waivers
In a notice issued Friday, the IRS provided guidance to persons filing certain returns on how to seek religious exemptions, hardship waivers, and other administrative exemptions provided by the IRS, from electronic filing requirements.
Location of millions of tax records uncertain, TIGTA says in IRS critique
A potential fraud issue exists because the IRS does not know the location of microfilm cartridges holding millions of business and individual tax records, a new TIGTA report shows.
Prop. regs. identify monetized installment sales as listed transactions
The IRS disagrees with court decisions requiring notice-and-comment rulemaking to identify listed transactions, but said it is identifying monetized installment sales transactions as listed transactions in proposed regulations “to avoid confusion and ensure consistent enforcement of the tax laws throughout the nation to prevent disruption of the IRS’s ongoing efforts to identify and examine abusive tax shelters.”
2024 filing season could be paperless, IRS says
Treasury and the IRS announced Wednesday that by filing season 2024, taxpayers will be able to go paperless if they choose to do so. And by filing season 2025, the IRS will digitize all paper-filed returns when they are received.
Proof-of-stake validation rewards are income in tax year received
The IRS ruled that cash-method taxpayers who stake cryptocurrency native to a proof-of-stake blockchain and receive cryptocurrency validation rewards must include the fair market value of the rewards in gross income in the year they are received.
Drug patent litigation expenditures are held deductible
The origin-of-the-claim test in Gilmore controls, the Court of Federal Claims concludes.
To combat fraud, IRS steps up ERC claim enforcement
Having made significant progress in the ongoing effort against fraudulent employee retention credit claims, IRS Commissioner Danny Werfel said the agency has entered a new phase of increasing scrutiny on dubious submissions while renewing consumer warnings against aggressive marketing.
Final regs. allow assessment of COVID-19 related tax credit refunds
The IRS issues final regulations that allow for the assessment of erroneous refunds of COVID-19 related paid sick leave, family leave, and employee retention credits.
IRS ends most unannounced revenue officer visits
IRS Commissioner Danny Werfel on Monday announced an end to unannounced home visits by IRS revenue officers, except in a few cases. The change is effective immediately.
Scams are surging in the summer, the IRS says
The IRS issued a warning for taxpayers to be wary of offers promising tax refunds or to “fix” tax problems, saying these emails or texts are part of a summer surge in tax scams.
At the ripe old age of 21, he’s advising the IRS on change
Aidan Hunt was appointed at age 20 to the IRS Advisory Council, a panel that advises the IRS commissioner and recommends administrative and policy changes.
IRS provides transition relief for change in beginning date for RMDs
A notice provides transition relief for the change in the required beginning date for required minimum distributions (RMDs) under the SECURE 2.0 Act and guidance related to certain specified RMDs.
Commissioner: We are progressing toward a user-friendly IRS
IRS Commissioner Danny Werfel said the Service’s transformation is in full swing, thanks to new infusion of cash that he says needs to keep coming.
How the IRS can avoid tax deadline confusion in disaster areas
The national taxpayer advocate recommended changes that range from one simple one the IRS can handle on its own to congressional action.
Prop. regs. clarify tax treatment of certain health insurance payments
New proposed regulations clarify that accident or health insurance payments are not excludable from an employee’s income where the payments are made without regard to amount of medical expenses incurred by the employee under Sec. 213(d) and the premiums or contributions for coverage are paid on a pre-tax basis.
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SPONSORED REPORT
Preparing clients for new provisions next tax season
As the 2025 filing season approaches, H.R. 1 introduces significant tax reforms that CPAs must be prepared to navigate. These legislative changes represent some of the most comprehensive tax updates in recent years, affecting both individual and corporate taxpayers. This report provides in-depth analysis and guidance on H.R. 1.
From The Tax Adviser
November 30, 2025
Digital asset transactions: Broker reporting, amount realized, and basis
October 31, 2025
Recent developments in estate planning
October 31, 2025
