Consider this article your periodic reminder that, for married taxpayers, filing jointly is an election and not the default (and certainly not the only) filing status option. It is important in a busy practice to remember to offer this option to clients who may benefit from filing separately, even if they don’t ask.
Are You Committing Filing Status Malpractice? Read More »
The IRS has issued a statement about a new settlement offer that is going out for conservation and historic preservation easement disputes. It is similar to previous offers, but there is one big difference. The partnership will not have to make a payment at the time that it accepts the offer. Other than that, it is similar to the deal offered in 2020. Taxpayers get to deduct what they are out-of-pocket as an ordinary deduction and are subject to a 10% penalty. In general, the out-of-pocket donation might be around 20% to 25% of the claimed charitable deduction. The Tax Court, on average, has been allowing 6%, although results vary. There is usually a 40% penalty in the decided cases.
Syndicated Easements: Fresh IRS Offer and the Perils of Post-BBA Gamesmanship Read More »
One would think that now, with summer doldrums and vacation days planned, Tax Court operations would slow and we could all go away. Not this month; six full-dress T. C. opinions and some Memos and miscellany fall like a summer cloudburst. Busy times.
TAX COURT ROUNDUP – August 2026 Read More »
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.
Lessons Learned from the Tax Court: What’s at Stake? Read More »
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.
What’s New With Hobby Loss: Recent Developments in Section 183 Read More »
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.
The Art of Income Shifting: Powerful Planning Strategies That Stand Up to Scrutiny Read More »
We’ve all said it: “Once busy season ends, we’ll fix this.” But the pressure never leaves, it just shifts. Extensions, quarter-end, planning season, and year-end come one after another. When a firm wants to grow, the real challenge is not, “Can we get more clients?” but, “Can we deliver quality service at scale without overburdening our team or diminishing client experience?” This is the true capacity problem behind growth.
The Capacity Problem: Why Your Firm Can’t Grow Until You Fix Delivery Read More »
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