The Ninth Circuit, affirming the Tax Court, recently held that to deduct a nonbusiness bad debt, the debt must be “wholly worthless,” and if the debtor reports cancellation-of-debt (COD) income, the discharged debt is not thereby presumed to be worthless to the creditor. Facts: From 2007 to 2010, Michael R.
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Tax
Tax Court denies $23 million façade easement deduction
The Tax Court denied a limited liability company’s (LLC’s) claimed charitable conservation contribution deduction under Sec. 170(h) for its donation of a façade easement because the LLC failed to establish that the building was a “certified historic structure” under Sec. 170(h)(4)(C). The court also rejected the LLC’s argument that the
Guidance on research or experimental expenditures under H.R. 1 issued
The revenue procedure advises taxpayers how to make various elections, file amended returns, and change accounting methods as provided under Section 70302 of the new law.
Draft 2026 Form W-2 includes boxes and codes for tips and overtime
The IRS said previously that it will not release a new form for 2025, even though the temporary H.R. 1 provisions are effective this year, but it will provide transition relief.
IRS seeks to fill ‘critical vacancies’ as workforce declines 25%
The IRS has asked some employees who accepted deferred resignation offers if they want to stay on the job.
Will budget, staff cuts impede IRS modernization? Former commissioner weighs in
Former IRS Commissioner Danny Werfel says the cuts, combined with the need to reengineer systems for the OBBBA, will make it difficult for the IRS to succeed at improving technology.
IRS should be more transparent when communicating phone service metrics, report says
The report by the Treasury Inspector General for Tax Administration called on the IRS to include more phone lines and to cover the entire fiscal year when reporting on its level of service and wait times.
Prop. regs. would modify reporting obligations for Form 8308, Part IV
The IRS issued proposed regulations that would modify partnerships’ reporting obligations for Part IV of Form 8308 with respect to sales or exchanges of certain interests in partnerships owning inventory or unrealized receivables.
IRS clarifies that Appeals case memos should be shared with taxpayers upon request
National Taxpayer Advocate Erin Collins wrote Tuesday in her blog that the IRS reminder of the language in the Internal Revenue Manual is a “meaningful step toward transparency.”
Billy Long out as IRS commissioner after less than two months
Long said Friday on X that he’s leaving the IRS and instead will be nominated to be ambassador to Iceland.
No 2025 information return or withholding table changes under OBBBA
The IRS announced Thursday that it is delaying changes to certain information returns, withholding tables, and reporting and withholding procedures until tax year 2026 “to avoid disruptions.”
AICPA presses IRS for guidance on domestic research costs in OBBBA
In its letter, the AICPA said small businesses that have not filed returns for the 2024 filing period face uncertainty about how to treat domestic research and experimental expenditures.
Date to start filing season not set despite IRS commissioner’s comment
Commissioner Billy Long said last week that the next filing season would start around Presidents Day, but the IRS said Tuesday that it has not set a date.
IRS includes several AICPA recommendations in corporate AMT interim guidance
In a notice issued Tuesday, the IRS said it intends to partially withdraw proposed regulations and issue revised proposed regulations.
Eleventh Circuit finds some FBAR penalties are excessive
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.
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.
Features
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New AICPA chair pitches a people-first profession
New AICPA Chair Jan Lewis shares why listening and service are central to her leadership approach. From advocating for small firms to navigating AI and strengthening the talent pipeline, Lewis outlines how she plans to steward a profession built on trust, relevance, and opportunity.
From The Tax Adviser
April 30, 2026
Current developments in taxation of individuals: Part 2
April 30, 2026
