IRS Releases Internal Revenue Bulletin 2026-32
The IRS has released Internal Revenue Bulletin 2026-32. [IRB 2026-32, 07/31/26]
Federal Tax Developments from Daily Tax Report ®
Developments
U.S. District Court Holds APA Review Unavailable for Foreign Gift Reporting Penalties
The U.S. District Court held that it lacked subject matter jurisdiction over a taxpayer’s Administrative Procedure Act challenge to penalties imposed under I.R.C. §6039F for failing to timely report foreign ...
U.S. Tax Court Sustains Civil Fraud Penalties Based on Double Bookkeeping Scheme
The U.S. Tax Court, in a memorandum decision, held that taxpayers were liable for civil fraud penalties under I.R.C. §6663 after the IRS established by clear and convincing evidence that ...
U.S. Tax Court Upholds Denial of Consolidated Net Operating Loss Deductions for Separate Return Limitation Years
The U.S. Tax Court held that a consolidated group could not deduct net operating loss carryovers inherited from a liquidated subsidiary because the losses arose in separate return limitation years ...
U.S. Tax Court Grants Taxpayer Innocent Spouse Relief for Mortgage Interest Deficiency
The U.S. Tax Court, in a summary opinion, held that a taxpayer was entitled to innocent spouse relief under I.R.C. §6015(c) because she lacked actual knowledge of the item giving ...
IRS Issues Revenue Procedure Providing Form 990 Filing Relief for Foreign FIFA World Cup 2026 Participants
The IRS issued a revenue procedure exercising its discretionary authority under I.R.C. §6033(a)(3)(B) to exempt certain foreign tax-exempt organizations participating in the FIFA World Cup 2026 from filing Form 990, ...
IRS Issues PLR Granting Extension to Allocate GST Exemption to Prior Trust Transfers
The IRS has issued a private letter ruling on I.R.C. §2642 and Treas. Reg. §26.2642 granting spouse a 120 day extension to allocate generation-skipping transfer (GST) exemption to trust transfers ...
IRS Issues PLR Allowing Transfer to Commonly Controlled Private Foundation Without Termination Tax
The IRS has issued a private letter ruling on I.R.C. §§507, 4940, 4941, 4942, 4944, 6033, and 6043 and Treas. Reg. §1.507 addressing private foundation asset transfers where a transferring ...
IRS Issues PLR Exempting Church-Affiliated Educational Organizations from Information Returns
The IRS has issued a private letter ruling on I.R.C. §170 and Treas. Reg. §1.6033 exempting church affiliated educational organizations below college level from Form 990 filing requirements provided they ...
IRS Issues PLR Granting Extension for Corporate Tax Classification Election
The IRS has issued a private letter ruling on Treas. Regs. §§301.9100 and 301.7701 and I.R.C. §7701 granting a limited liability company an extension of 120 days to file Form ...
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