Parker's Latest Federal Tax Articles:
FEBRUARY 2026
Legal Representative Is Personally Liable for $1.9 Million of Insolvent Corp's Tax Debt. 02/2026
"The court entered a judgment against Neuberger in the amount of $1,880,988. With respect to the government's request for a $3,330,664 assessment against Neuberger, the court found the government's assertion that "there is no grey area in this phase of the case" astonishing in light of the fact that the government failed to offer clear legal or evidentiary support for its position. The court also noted..."
Spouse With No Control Over Finances Wins Equitable Relief Under Sec. 6015(f). 02/2026
"The court found that Dr. Zaheen did not have actual knowledge of the 401(k) withdrawal since she did not learn about the transaction until she received an IRS notice in 2021. However, the court concluded that Dr. Zaheen had reason to know of the withdrawal. The court noted that Dr. Zaheen is a well-educated person who nevertheless signed the joint 2019 return without reviewing it."
Tax Court Chides Attorney for Apparent AI-Generated Case Cites. 02/2026
"Submitting a brief with fictitious caselaw, the court pointed out, is eligible for sanctions and a clear violation of the Federal Rules of Civil Procedure. However, in a footnote, the court said that it was not absolutely clear that Wagner used generative AI. The court concluded that "a bit of embarrassment" was sufficient for now, but it also noted that courts have begun to more seriously sanction lawyers who use AI as a shortcut in drafting."
Chief Counsel's Office Nixes Tax Strategy Using Charitable Donation of LLC Interests. 02/2026
Poultry Processor Scores Partial Win on Research Credits in Tax Court. 02/2026
Marijuana Business Is Prohibited from Claiming Employee Retention Credit. 02/2026
Notice of Deficiency Was Required Before Assessing Excess Advance PTC Payment. 02/2026
How to Handle Missing Forms W-2 and Forms 1099. 02/2026
College Properly Reported Settlement Payment to Former Student on Form 1099. 02/2026
Tax Court: Taxpayer Made a Bargain Sale, But At an Amount Less Than Deducted. 02/2026
JANUARY 2026
Fifth Circuit Reverses Tax Court; Rejects Self-Employment Tax "Passive Investor" Rule. 01/2026
IRS FAQs Provide Guidance On Deduction for Qualified Overtime Compensation. 01/2026
Proposed Regs Reflect OBBBA Change to Backup Withholding on Third Party Payments. 01/2026
Tax Court Rejects Executor's Attempt to Reduce Value of Estate. 01/2026
IRS Issues Interim Guidance on OBBBA Amendments to Bonus Depreciation Deduction. 01/2026
Second Circuit: Reckless Conduct Satisfies Willfulness Standard for FBAR Penalty. 01/2026
Feb 2nd Deadline is Approaching for Forms W-2 and 1099. Practice Tips & Observations Included. 01/2026
IRS Issues Proposed Regs on Car Loan Interest Deduction. 01/2026
IRS Provides Estimated Tax Penalty Relief for Sales of Qualified Farmland Property. 01/2026
Section 280E Expenses Disallowed in Calculating Reasonable Collection Potential. 01/2026
Updated Premium Tax Credit FAQs Reflect OBBBA Changes and Expiring Provisions. 01/2026
Popular: Top Tax Developments of 2025. 12/2025
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