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Current Federal Tax Developments

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Alvie N. Paschall and Patricia C. Paschall v. Commissioner of Internal Revenue, T.C. Memo. 2026-46 (June 4, 2026)

The litigation in Paschall v. Commissioner involves the tax treatment of cryptocurrency staking rewards received during the 2021 tax year. The petitioners, Alvie and Patricia Paschall, held Cardano tokens within an account on the digital asset pl...


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Igboke v. Commissioner, Bench Opinion, Docket No. 12275-24 (U.S. Tax Ct. June 3, 2026)

In the recent decision of Igboke v. Commissioner, the U.S. Tax Court addressed a fundamental issue regarding the deductibility of mortgage interest: whether taxpayers may claim a deduction for interest that was neither paid nor accrued during the relevant taxable year. For...


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Rising Rock Partners, LLC v. Commissioner, T.C. Memo. 2026-45, June 2, 2026

In a recent decision, the United States Tax Court addressed the limits of valuation methodologies regarding noncash charitable contributions for conservation easements. In Rising Rock Partners, LLC v. Commissioner (T.C. Memo. 2026-45), the court scrutinized the use of an income appro...


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REG-103193-26, June 1, 2026

The Internal Revenue Service (IRS) has issued a notice of proposed rulemaking (REG-103193-26) that will directly impact tax practitioners and executors managing decedent estates. The Treasury Department is proposing an increase in the user fee required for authorized persons requesting the issuance of an estate tax closing letter (also kno...


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Northeast Health Services, LLC v. United States, No. 24-2096T (Fed. Cl. May 28, 2026) Tri-State Memorial Hospital v. United States of America, Case No. 2:25-cv-00181-TOR (E.D. Wash. May 28, 2026)

The judiciary has recently offered divergent perspectives on the causal nexus required for Employee Retention Credit (ERC) eligibility. As explored in depth elsewhe...


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