A 2023 Tax Court decision upheld what many small business owners and tax practitioners have wondered about for some time. The court found that shareholders of an S corporation could exclude rental income paid to them by their S corporation for holding planning meetings in their homes. While the IRS and court found that the amounts charged by the shareholders were excessive, the court found the arrangement itself within the bounds of the law.
This article examines this case and underlying law and when and how this is a planning idea worth pursuing, the limitations and unknowns involved, and the policy implications of this long standing exclusion. The case is Sinopoli, TC Memo 2023-105 involving the exclusion at IRC Section 280A(g).
Using AI In Your Tax Practice? Choose The Nuclear Option
Amber Gray-Fenner, EA NTPI Fellow USTCP
I always know when something, especially something bad, is trending on social media. Why? Because I’m not on social media and I still hear about the issue. Lately, I’m getting disturbing reports of the cavalier attitude that many tax practitioners are taking towards the use of AI in their practices. Apparently even the IRS is catching on because in late June 2026 the Office of Professional Responsibility (OPR) sent a bulletin to practitioners reminding them of their obligations under Treasury Circular 230 and how the circular’s provisions apply to using AI in a tax practice. The bulletin includes a decent list of best practices, and I recommend reviewing the bulletin and the applicable sections of Circular 230 after you finish this article.
