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Current Federal Tax Developments

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First Source Employee Management, Inc. v. United States of America, Case No. 1:24-cv-02209-CEF, 2026 WL 3589421 (N.D. Ohio June 11, 2026).

The litigation originated from the Plaintiff’s operations as a professional employer organization under Chapter 4125 of the Ohio Revised Code and as a non-certified PEO and third-party payor under federal tax law. The Plaintiff fi...


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IRS Private Letter Ruling 202624006, June 12, 2026.

The matter involves a series of corporate reorganizations and tax elections concerning several entities, primarily a limited liability company (Y) and its parent corporation (X). Initially, Y was organized as an LLC under the laws of State on Date 1. The entity's operating agreement, adopted on Date 2, included prov...


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“Treasury Previews Education Freedom Tax Credit Guidance,” US Department of Treasury Release, June 10, 2026

In a significant move toward implementing the educational provisions of the Working Families Tax Cuts Act, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) have begun outlining the regulatory landscape for the new federal scho...


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William P. Wells and Ruth E. Wells v. Commissioner of Internal Revenue, T.C. Memo. 2026-49, June 10, 2026

The Internal Revenue Service (IRS) issued a Notice of Deficiency to William P. and Ruth E. Wells, disallowing carryover noncash charitable contribution deductions claimed for the 2019, 2020, and 2021 tax years. The deductions originated from a 2016 donation of re...


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Keith Schumacher and Rhonda Schumacher v. Commissioner of Internal Revenue, T.C. Memo. 2026-47 (June 9, 2026)

Keith and Rhonda Schumacher are "longtime hippophiles" who established Schumacher Quarter Horses (SQH) as a sole proprietorship in 2001 with the intention of breeding show horses. Dr. Schumacher is a licensed veterinarian and shareholder in a veterinary pract...


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