Practical analysis of IRS enforcement trends, digital asset tax developments, Tax Court decisions, and federal tax policy — written for taxpayers and practitioners who need to understand what's actually happening.
In Besicorp Group, Inc., et al. v. Commissioner, the Second Circuit held that Settlement Officers must verify compliance with IRC § 6751(b)(1) during CDP hearings, even for penalties assessed via a Tax Court decision. The IRS will likely seek an en banc rehearing of the case in the Second Circuit and argue against it in other circuits.
Read ArticleIn Paschall v. Commissioner, T.C. Memo. 2026-46, the US Tax Court held that staking rewards received through a custodial staking-as-a-service arrangement are taxable as ordinary income at fair market value when received rather than at when they are sold in the future.
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