Parker Tax Pro Library

05/28/2026

Final Regs Modify Partnership Reporting Requirements for Unrealized Receivables

"The IRS issued final regulations that modify information reporting obligations with respect to sales or exchanges of interests in partnerships owning inventory or unrealized receivables (i.e., Code Sec. 751(a) assets)."

https://www.parkertaxpublishing.com/public/APA-challenge-ESOP.html

05/26/2026

District Court Dismisses APA Challenge to IRS ESOP Information Request Procedure

"A district court dismissed a lawsuit brought by taxpayers that established an employee stock ownership plan (ESOP), arguing that the IRS violated the Administrative Procedure Act (APA) when it sent the ESOP a Form 4564, Information Document Request, stating that the ESOP was not qualified under Code Sec. 401(a) and the trust was not exempt under Code Sec. 501(a)."

https://www.parkertaxpublishing.com/public/APA-challenge-ESOP.html

05/21/2026

Taxpayer Advocate Encourages Taxpayers to Claim COVID-Era Refunds Before July 10

"In an April 30 blog post, the National Taxpayer Advocate stated that tens of millions of taxpayers may be entitled to refunds or abatements of penalties and interest the IRS assessed during the nearly 3.5-year COVID-19 federal disaster period if they file claims by July 10, 2026."

https://www.parkertaxpublishing.com/public/covid-era-refund-deadline.html

The National Taxpayer Advocate, April 30 blog post. Kwong v. U.S.

05/19/2026

Tax Court Won't Provide a Remedy for IRS Failure to Provide Estate Valuation Statement

"The Tax Court rejected an estate's motion seeking to preclude the IRS from asserting its determined value of the estate as a consequence of the alleged IRS's failure to provide a written statement explaining the basis of the valuation as required within 45 days of the estate's request under Code Sec. 7517(a)."

https://www.parkertaxpublishing.com/public/irs-estate-valuation.html

05/12/2026

Taxpayer Advocate Encourages Taxpayers to Claim COVID-Era Refunds Before July 10

"In an April 30 blog post, the National Taxpayer Advocate stated that tens of millions of taxpayers may be entitled to refunds or abatements of penalties and interest the IRS assessed during the nearly 3.5-year COVID-19 federal disaster period if they file claims by July 10, 2026."

https://www.parkertaxpublishing.com/public/covid-era-refund-deadline.html

04/30/2026

Court Rejects Proposed Settlement Allowing Churches to Endorse Political Candidates

"A district court held that it did not have jurisdiction to enter a proposed consent judgment, agreed to by the IRS two churches and two other nonprofit groups focused on religious practice, that would have declared unconstitutional the provision in Code Sec. 501(c)(3) that bars exempt organizations from participating in political campaigns (i.e., the Johnson Amendment). "

https://www.parkertaxpublishing.com/public/tax-anti-injunction-act.html

National Religious Broadcasters, et al. v. Bessent et al., 2026 PTC 76 (E.D. Tex. 2026).

04/28/2026

District Court Vacates Micro-Captive Listed Transaction Regulation

"A district court held that the IRS exceeded its statutory authority in designating certain micro-captive transactions as listed transactions in Reg. Sec. 1.6011-10 and therefore declared the regulation unlawful and vacated it. The court found that under Code Sec. 6707A, micro-captive transactions must be presumptively tax avoidant in order to be described as listed transactions, and the IRS failed show that the transactions described in Reg. Sec. 1.6011-10(c) met that standard. Drake Plastics Ltd. Co., et al. v. IRS, 2026 PTC 87 (S.D. Tex. 2026)."

https://www.parkertaxpublishing.com/public/irs-micro-captive-transactions.html

04/27/2026

IRS Issues Proposed Regs on 1099 Reporting Thresholds, Wagering Loss Limitation

"The IRS issued proposed regulations under Code Secs. 6041 and 6041A relating to the increased threshold for reporting payments made in the course of a trade or business under the One Big Beautiful Bill Act (OBBBA) (Pub. L. 119-21) and the corresponding backup withholding regulations under Code Sec. 3406. The proposed regulations also update the regulations under Code Sec. 165 to reflect the 90 percent limitation on wagering losses enacted by the OBBBA. REG-113229-25."

https://www.parkertaxpublishing.com/public/irs-regs-reporting-thresholds.html

04/21/2026

IRS Provides Estimated Tax Penalty Relief to Qualifying Farmers and Fishermen

"The IRS provided a waiver of the addition to tax under Code Sec. 6654 for underpayment of estimated income tax by farmers and fishermen who have only one required installment payment (instead of four quarterly payments) due on January 15 (i.e., qualifying farmers and fisherman)."

https://www.parkertaxpublishing.com/public/tax-penalty-relief-farmers-fishermen.html

04/17/2026

Tax Court Dismisses Petition Filed By Suspended Corporation

"The Tax Court held that Arbor Vita did not have the capacity to file a petition because under California law its corporate revival did not relate back to the date it filed its petition. Therefore, the court did not have jurisdiction."

https://www.parkertaxpublishing.com/public/petition-rules-tax-court.html