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Supreme Court Rules Tax Court Lacks Jurisdiction Where IRS Withdraws Levy (Commissioner v. Zuch, SCt.)
The U.S. Tax Court lacks jurisdiction over a taxpayer’s appeal of a levy in a collection due process hearing when the IRS abandoned its levy because it applied the taxpayer’s later year overpaymen...

IRS Collects More Than $5 Trillion In 2024 (IR 2025-63)
The Internal Revenue Service collected more than $5.1 trillion in gross receipts in fiscal year 2024. It is the first time the agency broke the $5 trillion mark, according to the 2024 Data Book, an a...

Change of Accounting Method Procedures Updated (Rev. Proc. 2025-23)
The IRS has released guidance listing the specific changes in accounting method to which the automatic change procedures set forth in Rev. Proc. 2015-13, I.R.B. 2015- 5, 419, apply. The latest guidan...

Additional Transition Relief Provided for Brokers Required to File Form 1099-DA (Notice-2025-33; IR-2025-67)
The Treasury Department and IRS have issued Notice 2025-33, extending and modifying transition relief for brokers required to report digital asset transactions using Form 1099-DA, Digital Asset Proc...

Tax Court Lacked Jurisdiction as IRS Failed to Establish Valid Notice of Deficiency (Cano, TCM)
The IRS failed to establish that it issued a valid notice of deficiency to an individual under Code Sec. 6212(b). Thus, the Tax Court dismissed the case due to lack of jurisdiction....

TEFRA Partnership not Entitled to Exclude Partners’ Distributive Shares from Self-Employment Income (Soroban Capital Partners LP, TCM)
A limited partnership classified as a TEFRA partnership was not entitled to exclude its limited partners’ distributive shares from net earnings from self-employment under Code Sec. 1402(a)(13). The...

How Do I? Get back start-up expenses in starting a business as quickly as possible
The American Jobs Creation Act of 2004 (2004 Jobs Act) changed the rules for start-up expenses in both favorable and unfavorable ways. Start-up expenditures are amounts that would have been deductible...

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