The appeals court held that some of a taxpayer’s FBAR penalties were disproportional to the offense and thus an excessive fine under the Eighth Amendment.
Advertisement
TOPICS
Tax
LLC lacks reasonable cause for information-reporting failures
An auto dealership failed to prove that its software operated incorrectly or that it had adequate controls to identify noncompliance, the Tax Court held.
Tax Court denies constitutional challenge to IRS Appeals officers’ and supervisors’ appointments
The Tax Court follows its prior holding on the application of the Appointments Clause to the staff of the IRS Independent Office of Appeals, finding that the prior holding was not altered by amendments under the Taxpayer First Act and intervening judicial decisions.
Line items
IRS hotline questions resolved faster in 2025; concern grows about agency’s future … Revenue agents who conduct audits lead IRS job losses … AICPA makes recommendation for updated Form 8971 instructions … HSA inflation-adjusted maximum contribution amounts for 2026 announced … Basis-shifting transaction-of-interest regulations to be removed … AICPA publishes additional resources in push to preserve PTET SALT deduction
AICPA supports bill that lets married domestic violence victims file taxes as single
The bill would empower survivors of domestic abuse or spousal abandonment to file taxes without contacting their abuser.
New commissioner confident IRS can implement OBBBA’s tax provisions
Commissioner Billy Long explained his management philosophy at the 2025 Tax Summit of the National Association of Enrolled Agents, where he said IRS employees will be able to implement the OBBBA’s tax provisions.
IRS staff cuts could put burden on practitioners to explain OBBBA
A retired IRS communications executive told the AICPA’s Town Hall that employees will be challenged to explain tax changes in the massive law.
IRS advises of Tuesday deadline to maintain Business Tax Account access
The IRS warned that those who do not revalidate accounts by Tuesday will need to request access to the account again, either as a designated official or other user type.
Dealing with natural disasters: IRS relief efforts leave some wanting
How can the IRS best assist victims of natural disasters? The AICPA asked victims how long they had to wait for assistance and asked CPAs the best courses of action.
Congress passes act allowing tax relief when a state declares disaster
A bill supported by the AICPA is “a major win for taxpayers and tax practitioners,” according to a statement by President and CEO Mark Koziel. The bill, which now heads to President Donald Trump for his signature, is intended to speed up the granting of tax deadline extensions after a disaster.
AICPA: Guidance needed on catch-up contributions under Roth mandate
In a letter to Treasury and the IRS, the AICPA requested guidance on language in proposed regulations issued in January.
It’s no joke: Being nice is among this attorney’s top ways to deal with the IRS
Being nice is one of tax controversy attorney Melissa Wiley’s ways of getting answers from the IRS, which also includes knowing the Internal Revenue Manual and using self-service tools.
Tax provisions in the One Big Beautiful Bill Act
The bill extends portions of the Tax Cuts and Jobs Act, provides deductions to eliminate income taxes on certain tips and overtime pay, and addresses other tax priorities of the Trump administration.
AICPA recommends changes to mandate ending federal disbursements by paper check
An executive order issued in March requires the Treasury secretary to cease issuing paper checks for all federal disbursements and requires all payments made by the federal government to be electronically processed.
AICPA tax priorities and wins in the budget bill now with the House
An AICPA tax leader updates listeners on tax-related points in the Senate-approved budget bill and addresses a recent report to Congress about the potential for IRS service levels to decline. Listen to the podcast episode or read the Q&A.
IRS withdraws proposed regs. governing built-in losses and gains
The IRS said Tuesday that it expects to issue a revised notice of proposed rulemaking after it studies the issues addressed in the 2019 proposed regulations.
E-filed Tax Court petition’s completed signature block is valid
The court denies the IRS’s motion to dismiss the taxpayers’ petition as not properly signed.
Deductibility of theft losses for victims of certain scams
In the case of an individual, theft losses stemming from scams through fraud and deceit are disallowed for tax years 2018 through 2025 unless the transaction was entered into for profit.
Tax Court denies limited-partner exception to self-employment tax
The court again applies a functional-analysis test, as it had in Renkemeyer and Soroban.
Line items
IRS can make it easier to leave assets to younger generations, AICPA says … Pandemic-era ERC started with good intentions, ending with frustration … AICPA recommends prop. regs. changes for some retirement savings plans … Bills dealing with tax administration, disaster victims pass House
Features
SPONSORED REPORT
How to find the right CAS clients
The key to success with CAS is selecting the best clients. Tools like ideal client profiles (ICPs), buyer personas, and even artificial intelligence can help identify the businesses that best fit each CAS practice.
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
