CURRENT EDITION

Lessons Learned from the Tax Court: What’s at Stake?
Astute readers of this publication may recognize that I frequently write on Cryptocurrency and also on Tax Court cases. It feels like Christmas to me to be able to write about a tax court case about crypto. This is only the Third Tax court case to even mention crypto, and the first to look at the underlying principles of taxation. (The other two were about including crypto assets in a CDP hearing and a frivolous tax protester argument). Today’s case, Paschall v. Commissioner, is about the taxation of staking income.
READ MORETAX COURT ROUNDUP – December 2025
An updated website launches, the economic substance codification is applied, Loper Bright Entrprs. marches on but hits the statute, and the syndicated conservation easement flood continues, as Tax Court pushes through the government shutdown. The biennial examination for non-attorney admission to Tax Court took place as scheduled.
Read MoreLessons Learned from the Tax Court: The Root of the Issue
When is a business really a business? As Supreme Court Justice Potter Stewart said in 1964, “I know it when I see it.” The US Tax Court, however, maintains a slightly less subjective standard. The Roots were pretty sure they were running a bona fide business; the IRS, however, didn’t share the sentiment. And since we’re reading about them in a segment called “Lessons Learned,” one should assume it did not go the way the Roots would have liked.
Read MoreThe Lessons From The Supreme Court Zuch Opinion
There is a great scene in the movie On The Basis Of Sex. The actors portraying Ruth Bader Ginsburg and her husband, Martin Ginsberg, a very high-level tax attorney, early in their careers are reading in separate rooms. He comes in with something he wants her to read and she snaps that she doesn’t read Tax Court cases. In that moment she showed her future as a Supreme Court Justice. Not many Tax Court cases reach the Supreme Court. So when one does it’s exciting. And, as it happens, Commissioner of Internal Revenue v Zuch contains some practical lessons worth considering.
Read MoreFractional Art Investing Is Real — How To Advise Your Clients On The Tax Consequences
In mid-November a portrait of a young Vietnamese woman by the artist Gustav Klimt, which was part of the estate of the late Leonard Lauder (the cosmetics billionaire), was sold at a Sotheby’s auction for $236.4 million. It set the record for the most expensive work of modern art ever sold at auction according to Bloomberg. That’s probably out of reach for most of our clients. But what if they could join together to buy an interest in the painting with an entity holding the asset? That’s the idea behind the burgeoning fractional art market. While, in general, the art market has been struggling for a few years, the fractional art market has been expanding. According to the website Digital Original, “Fractional art ownership is no longer a niche concept – it’s a growing investment trend that’s accessible, flexible, and supported by cutting-edge technology.” What, you may be asking, does this have to do with taxes? It may be more than you think for your high-net-worth clients. As a trusted advisor it’s important that you are aware of both the types of investment opportunities your clients may be buying into and the tax consequences.
Read MoreHow to Build a Better Client List (and Why It Matters More Than You Think)
You’ve got a packed calendar, a nonstop inbox, and maybe even a waitlist. But if your client list feels more like a burden than a blessing, you’re not alone. Many tax professionals find themselves weighed down by clients who are difficult, unprofitable, or simply not a good fit. What if the secret to a more profitable and fulfilling practice wasn’t more clients—but better ones? In this article, we will explore a simple, strategic framework to reshape your client base—one that leads to higher revenue, fewer headaches, and greater job satisfaction. From identifying red flags to implementing screening tools and disengaging with misaligned clients, these steps can help you build a practice you actually enjoy.
Read MoreEffortlessly Convert Leads: How AI Bots Can Handle FAQs and Drive Appointments for Accountants
AI technology, particularly in customer service automation, is now more accessible than ever. AI-powered bots are a powerful tool for businesses, including accounting firms, empowering them to improve efficiency, enhance client engagement, and ultimately drive conversions. For accountants, AI bots provide a unique opportunity to take control of frequently asked questions (FAQs) from prospects, turning these interactions into booked appointments. In this article, I will discuss how you can leverage the power of AI bots to efficiently handle FAQs and convert prospects into clients, all while saving precious time and resources. By the end of this article, you’ll have the knowledge to set up an AI bot that resonates with your prospects, builds trust, and seamlessly guides conversations toward scheduled appointments, allowing you to focus on higher-value tasks.
Read MoreYear-End Tax Planning Under the One Big Beautiful Bill Act (OBBBA)
The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, doesn’t reinvent the tax code it refines it. Much like its predecessor, the Tax Cuts and Jobs Act (TCJA), it keeps many familiar provisions in play: lower rates, expanded SALT flexibility, and broader deductions. But here’s the real story: While most tax pros are busy memorizing what stayed the same, the planners who will win 2025 are the ones spotting what just became possible. OBBBA quietly opens a handful of powerful new planning windows — each one capable of delivering real, measurable savings for the right client. The key is knowing which changes are worth your time… and which are just political garnish. Below, we’ve curated the most strategic, high-impact moves to make before year-end 2025, the ones that separate the advisors who explain the law from those who leverage it. Most tax pros will stop at what changed. The smart ones will keep reading to learn how to use it.
Read MoreTiming is Everything: A Conversation Between a Tax Pro and Client
The new permanent bonus depreciation regime will bring back the old playbook: lever up to buy a rental property and bonus depreciate everything under the sun. But the tax savvy general partners know that WHEN to depreciate is just as important as how to depreciate.
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CURRENT EDITION

Lessons Learned from the Tax Court: What’s at Stake?
Astute readers of this publication may recognize that I frequently write on Cryptocurrency and also on Tax Court cases. It feels like Christmas to me to be able to write about a tax court case about crypto. This is only the Third Tax court case to even mention crypto, and the first to look at the underlying principles of taxation. (The other two were about including crypto assets in a CDP hearing and a frivolous tax protester argument). Today’s case, Paschall v. Commissioner, is about the taxation of staking income.

What’s New With Hobby Loss: Recent Developments in Section 183
Recent developments in the Section 183 (Hobby loss) area have not led me to change my basic conclusions. Taxpayers who have a sincere objective of ultimately making a profit should not hesitate to claim losses from the underlying activities. That is so even if you believe that profits are improbable. It is critical that they meet the standard of behaving in a businesslike manner. The other regulatory factors should not be ignored, but often there is not that much you can do about them. Reilly’s 18th Law of Tax Planning – Honest objective trumps realistic expectation.

The Art of Income Shifting: Powerful Planning Strategies That Stand Up to Scrutiny
Income shifting strategies address taxation at its most fundamental level by directing income to taxpayers in lower brackets or with offsetting deductions. Unlike many tax strategies that merely time recognition or enhance deductions, effective income shifting can permanently reduce the tax burden on a given dollar of income—often creating tax savings that compound year after year. In this article, we’ll explore systematic approaches to income shifting that create extraordinary value for clients while maintaining impeccable compliance.








