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Current Federal Tax Developments

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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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Estate of Anne Milner Fields, Deceased, Bryan K. Milner, Executor v. Commissioner of Internal Revenue, No. 25-60403 (5th Cir. June 8, 2026).

The United States Court of Appeals for the Fifth Circuit recently issued a significant ruling regarding the boundaries of the bona fide sale exception under I.R.C. § 2036(a). In Estate of Anne Milner Fields v. Commissioner


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Oregon Environmental Council v. Internal Revenue Service, No. 25-4400 (D.D.C. June 6, 2026)

The landscape of clean energy tax planning underwent a seismic shift following the issuance of Internal Revenue Service (IRS) Notice 2025-42. This technical analysis examines the recent decision by the United States District Court for the District of Columbia in Oregon Env...


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