Current Federal Tax Developments

Robert E. Braun v. Commissioner of Internal Revenue, Docket No. 25467-21S (U.S. Tax Court Oct. 20, 2026) (Bench Opinion by STJ Diana L. Leyden)

Executive Summary

Tax practitioners frequently encounter clients who misapprehend the federal income tax consequences associated with whole life insurance policy conversions, lapse events, and...

Rev. Proc. 2026-35, November 5, 2026

Overview and Legislative Authority

The Internal Revenue Service released Revenue Procedure 2026-35, establishing the annual inflation adjustments for key tax provisions applicable to tax year 2027. Under Section 1 of the Revenue Procedure, the IRS emphasizes the underlying authority and potential f...

Moiseshyn v. Commissioner, T.C. Memo. 2026-114, November 4, 2026

Executive Summary

In Moiseshyn v. Commissioner, the United States Tax Court addressed a bit of confusion the taxpayers encountered when handling employee stock plan dispositions. The taxpayers believed they could defeat an IRS deficiency determination for omitte...

Columbus Orthopaedic Clinic, P.A. v. United States, Civil Action No. 1:25-cv-78-RPC-RP (N.D. Miss. Oct. 30, 2026)

For Certified Public Accountants (CPAs) and Enrolled Agents (EAs) representing clients facing Employee Retention Credit (ERC) audits or litigation under Internal Revenue Code (I.R.C.) § 3134, the decision in Columbus Orthopaedic Clinic, P.A. v....

Glass Warehouse, LLC v. Commissioner, T.C. Memo. 2026-111, November 2, 2026

Executive Summary and Practice Insights

For tax practitioners advising closely held corporate clients, Glass Warehouse, LLC v. Commissioner serves as a stark reminder of the foundational evidentiary burdens required under the Internal Revenue Code. Th...