July 9th, 2025
Highlights of the Tax Provisions of OBBB Act
On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBB), marking one of the most significant tax reforms in recent years. The sweeping changes to the federal tax code…
July 7th, 2025
June Federal Tax Update
INDIVIDUALS In Beaverdam Creek Holdings v. Commissioner TC Memo 2025-53, the Tax Court concluded that a partnership had claimed a conservation easement based on a “preposterous” financial model and allowed a deduction of about $193,000…
June 11th, 2025
May Federal Tax Update
INDIVIDUALS In Stevens v. Commissioner, TC Memo 2025-45, the Tax Court concluded that a $34.2 million tax deduction for an interest accrual on a “loan” arrangement to offset a business sale for $36.2 million was…
May 8th, 2025
April Federal Tax Update
INDIVIDUALS In Zajac v. Commissioner, TC Memo 2025-33, the Tax Court found that one-half of a $35,001 settlement for the taxpayer’s arrest and incarceration for allegedly beating his wife which charges were dropped when not…
April 8th, 2025
March Federal Tax Update
INDIVIDUALS In Jaha v. Commissioner, TC Memo 2025-26, the Tax Court determined that a husband was domiciled in California rather than Oregon when he earned income from a business such that community property law made…
March 6th, 2025
February Federal Tax Update
INDIVIDUALS In Green Valley Investors LLC v. Commissioner, TC Memo 2025 – 15, IRS reduced a conservation easement deduction from the $90 million that was claimed down to $1.15 million, rejecting arguments intended to avoid…
February 4th, 2025
January Federal Tax Update
INDIVIDUALS In Franklin v. Commissioner, TC Memo 2025-8, the Tax Court determined that a withdrawal of $155,000 by an Alabama county sheriff from an account used to fund meals for jail inmates that was invested…
January 9th, 2025
December Federal Tax Update
INDIVIDUALS In Bruyea v United States, 134AFTR 2d2024-6310, the US Court of Federal Claims became the second court to determine that a treaty-based (in this case Canada) foreign tax credit applies against the Net Investment…
November 1st, 2024
October Federal Tax Updates
INDIVIDUALS In Warren v. Commissioner, TC Summary Opinion 2024-20, the Tax Court declined to classify an engineer as a “real estate professional” as he worked as an employee on a full time basis and claimed…
June 1st, 2024
May Federal Tax Updates
INDIVIDUALS In Excelsior Aggregates LLC v. Commissioner, TC Memo 2024-60, in a decision applied to 13 cases, the Tax Court doubted the value of conservation easements restricting sand and gravel mining and reduced the deduction…
