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The U.S. Tax Court, in Lake Jordan Holdings, LLC v. Commissioner, T.C. Memo. 2025-123, delivered a thorough rejection of an egregious valuation claimed for a syndicated conservation easement, underscoring the necessity of grounding valuations in objective market realities rather than speculative assumptions. This memorandum opinion details the continuation of the "de...
The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) announced their intent to issue forthcoming proposed regulations to implement the new individual tax credit provision codified as § 25F of the Internal Revenue Code (Code). This section was added by § 70411 of Public Law 119-21, 139 Stat. 72 (July 4, 2025)</str...
The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued Notice 2025-72 to announce their intent to issue forthcoming proposed regulations addressing two key areas impacted by recent legislation. Specifically, the notice details plans for proposed regulations under Section 70352 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commo...
This article examines the decision of the United States Court of Federal Claims in Quinones v. United States, No. 24-810 (Fed. Cl. Nov. 21, 2025), focusing on the government’s successful recovery of an erroneously issued tax refund based on fraudulent reporting practices. The memorandum order and opinion issued by Judge Tapp provides crucial clarity regarding the app...
This supplemental memorandum opinion addresses a taxpayer’s motion for reconsideration regarding the application and validity of Treasury Regulations governing the deduction of losses from activities not engaged in for profit, specifically in the wake of the Supreme Court’s ruling in Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024). This analysis focuses ...
