The IRS could not require that the taxpayer prove, as opposed to represent, that it had enough assets to pay any imputed underpayment, based on the regulation’s plain text.
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Tax
Lack of facts precludes equitable tolling of 30-day filing deadline
The Tax Court dismissed a taxpayer’s petition due to a missed filing deadline and lack of any facts that would entitle him to equitable tolling of the deadline.
ERC supplemental claim process opened for third-party payroll companies
The IRS announced that it will open a supplemental claim process to help third-party payers and their clients resolve incorrect claims for the employee retention credit. The deadline is Nov. 22.
IRS increases special per diem rate for business travel
The special per diem rates that a taxpayer uses in travel and business expenses will be higher starting Oct. 1, as provided by the IRS.
JofA highlights: Tackling accounting’s talent shortage, ChatGPT tips
The JofA’s editor-in-chief highlights the news, features, and advice that CPAs will find useful in recently published and upcoming issues of the magazine. Listen to the podcast episode or read the transcript.
Final regs. issued on consistent-basis and basis-reporting rules
The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements.
Proposed regs. would exclude tribal general welfare benefits from income
The first proposed regulations under Sec. 139E set out the requirements for excluding Indian tribal general welfare benefits from income.
Corporate AMT proposed regulations issued; some penalties waived
The IRS issued proposed regulations providing guidance on the corporate alternative minimum tax (AMT) and a notice that waives the penalty for failure to pay estimated tax with respect to the corporate AMT for 2024.
IRS seeks comments on SECURE 2.0 saver’s match contributions
Treasury and the IRS issued a notice on saver’s match contributions to be paid by Treasury under provisions of SECURE 2.0.
Cryptoasset ‘staking’ challenge dismissed as moot after government’s concession
Sixth Circuit affirms district court’s holding that the taxpayer’s refusal to cash a refund check did not keep the controversy alive in his case.
Line items
Supreme Court: Insurance proceeds increase corporation’s estate tax value … 9 months into ERC claim processing moratorium, still a waiting game … National taxpayer advocate: TikTok a difficult adversary for IRS … Expert warns: IRS has what it needs to pursue more audits … Bias possible in IRS program for auditing refundable credit returns … AICPA makes recommendations to IRS on next Priority Guidance Plan
Credit card reward liabilities may be eligible for recurring-item exception
The Office of Chief Counsel approves
accrual of liability, distinguishing the
situation in a CCA from that of Giant
Eagle, Inc.
Taxation of influencers: Gifts with strings attached?
Individuals promoting retail brands to their online audience may need to report taxable compensation for any benefit received.
Tax Court lacks jurisdiction because notice of deficiency was invalid
The court held that the notice was not sent
to the taxpayer’s last known address.
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.
Potential effects of Loper Bright and Corner Post on tax practitioners
An AICPA tax leader explains the potential ramifications of two recent Supreme Court decisions on tax regulation. Listen to the podcast episode or read the Q&A.
Employers now have interim guidance on student loans and retirement plans
The IRS provided guidance for sponsors of 401(k) and similar retirement plans that provide matching contributions based on eligible student loan payments made by participating employees.
AICPA joins coalition to fight intensifying tax scams, schemes
The Coalition Against Scam and Scheme Threats (CASST), convened at the request of IRS Commissioner Danny Werfel, will work toward having new protections in place by the 2025 filing season.
Businesses with dubious ERC claims have another chance with the IRS
The IRS said Thursday it will reopen its voluntary disclosure program to allow businesses to correct questionable claims for the pandemic-era employee retention credit.
IRS releases updated draft of Form 1099-DA for digital assets
The most recent draft of the form for reporting digital asset transactions reflects the final regulations for custodial broker reporting that the IRS released in June.
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From The Tax Adviser
March 31, 2026
Current developments in taxation of individuals: Part 1
March 31, 2026
Current Developments in Taxation of Individuals: Part 1
March 6, 2026
