The court again applies a functional-analysis test, as it had in Renkemeyer and Soroban.
Advertisement
TOPICS / TAX
IRS practice & procedure
IRS staffing, budget cuts threaten 2026 filing season, taxpayer advocate says
After a successful 2025 tax filing season, the loss of over 25% of staff and a 37% drop in funding leave the status of the 2026 season in doubt, the national taxpayer advocate’s midyear report said.
Lessons from a CPA whose firm delivered a ‘textbook response’ to data breach
The owner of a CPA firm in Texas told attendees at an AICPA & CIMA ENGAGE 25 session on data security that the breach was one of the hardest things she had experienced in her career, yet she came out of it with clients still viewing her positively.
AICPA makes Priority Guidance Plan recommendations to IRS
In addition to its 183 recommendations for the IRS plan, the AICPA encouraged the agency to continue to pursue tax simplification.
Supreme Court: Tax Court lacks jurisdiction after removal of levy
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.
IRS provides additional transition relief for certain digital asset brokers
The relief applies to brokers who must report certain digital asset sales and exchanges on Form 1099-DA and is in response to public comment that brokers need more time to comply.
Senate confirms Billy Long as IRS commissioner
The former Missouri congressman is the sixth head of the IRS since January. He was confirmed by a vote of 53-44.
Automatic accounting method changes list updated by IRS
On Monday, the IRS provided a list of changes in tax accounting methods to which the automatic change procedures in Rev. Proc. 2015-13 apply. The list includes 17 changes described as significant.
IRS budget request cuts 20% of employees in 2026, increases phone help
Treasury released the Congressional Budget Justification, which also would cut the IRS budget by 37% from the fiscal year 2025 operating plan to the fiscal year 2026 request.
Simplified method to determine corporate AMT applicable status issued
A notice issued by the IRS with interim guidance for the application of the corporate alternative minimum tax offers an optional simplified method for determining applicable corporation status under Sec. 59(k).
Funds withdrawn from jail food money account were a loan, not embezzlement income
An unauthorized loan was not includible in the taxpayer’s income; however, expenses incurred in connection with her employment as a county sheriff were not deductible.
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.
IRS hotline questions resolved faster in 2025; concern grows about agency’s future
An annual survey of AICPA members about IRS service showed the majority of respondents are concerned that political distractions will affect agency funding and administration in the future.
AICPA recommends changes to prop. regs. on PTEP, related basis adjustments
The recommendations, sent Tuesday in a letter to Treasury and the IRS, include that the IRS expressly allow taxpayers to rely on proposed regulations until they are final.
Why the PTET SALT deduction is the AICPA’s ‘No. 1 priority’
An AICPA tax leader updates listeners on key points of the tax portion of the House budget bill. She also details some of the AICPA’s sticking points and potential “wins” — and explains why IRS service may soon decline. Listen to the podcast episode or read the Q&A.
AICPA: Contingent fee provision in tax bill would help unscrupulous tax preparers
In a letter to congressional committee leaders, the AICPA said Congress should strike language from the tax bill that bars Treasury from regulating contingent fees.
IRS reduces user fee for estate tax closing letters
The receipt of an estate tax closing letter generally indicates that the estate tax return’s IRS examination is closed. Final and proposed regulations lowered the fee by $11.
Revenue agents who conduct audits lead IRS job losses
The IRS lost 11% of its staff in the first three months of 2025, with revenue agents who conduct audits accounting for the largest percentage of those who left, the Treasury Inspector General for Tax Administration said in a report.
AICPA makes recommendation for updated Form 8971 instructions
In a letter to the IRS, the AICPA recommended that the agency provide further guidance in two areas of new instructions for Form 8971, Information Regarding Beneficiaries Acquiring Property From a Decedent.
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.
Features
FROM THIS MONTH'S ISSUE
Real-life ways small firms use AI
Learn how four small firms use artificial intelligence to automate processes while maintaining strong oversight.
From The Tax Adviser
July 31, 2026
Current developments in S corporations
July 31, 2026
