Get your popcorn ready because there is nothing more exciting than the intersection of sports and tax! As a former Division II athlete, the current state of college sports and Name, Image, and Likeness (NIL) deals is fascinating.  Student-athletes typically focus on maintaining good grades, practicing hard, and playing to the best of their abilities, but the Internal Revenue Code (Code) is unlike any playbook they’ve ever seen. Based on a recent hearing, it appears that Congress is aware of…More

Every January, businesses race to issue Forms W-2, 1099, and 1099-NEC, but a small typo in a Social Security Number (SSN) or Taxpayer Identification Number (TIN) can turn into a surprisingly expensive sequel. The IRS requires information returns to include a correct name/TIN combination. If the name doesn’t match the TIN — or the TIN is missing entirely — the IRS can assess substantial penalties and interest. Given the current administration’s focus on illegal immigration, it is imperative that businesses…More

Classroom participation points may boost a child’s grade in history class, but merely raising your hand won’t get you far with the IRS.  The passive activity loss rules under I.R.C. § 469 can make a real economic loss feel like a tax detention: present on the books, but not allowed as a deduction against active income.  For CPAs and tax advisors, the issue is often not whether there was a loss or the amount, but more whether the taxpayer accrued enough…More

On July 1, 2026 the IRS unveiled a new portal for Kwong related refund claims. Taxpayers who want file Forms 843 claiming a refund for interest or penalties that accrued between January 20, 2020 and July 10, 2023 can file claims electronically through the IRS portal. Taxpayers can still paper file Forms 843 through normal refund claim procedures. The IRS clarifies that the portal is only for claims related to fully paid interest or penalties. That means taxpayers who are protectively…More

At the NYU Tax Controversy Forum last week, (former?) Acting IRS Chief Counsel Ken Kies commented on the IRS conservation easement settlement initiative and noted that the IRS is looking into what he calls “easement-like” charitable donations of medical devices. With the dog days of summer quickly approaching, Mr. Kies provided a helpful reminder that the IRS’s expensive crusade against charitable-minded taxpayers continues. Wagging and Bragging: IRS Counsel Pushes Easement Settlement Initiative With respect to the easement settlement initiative, Mr. Kies…More

The current administration’s focus on tax-exempt organizations is no secret.  But the recent release of the IRS Databook for FY25 shows that the IRS is following through on the administration’s publicly announced objectives.  Based on information from IRS Databooks for the last 10 fiscal years, the year-over-year increase (FY24 to FY25) in IRS examinations of tax-exempt organizations is extraordinary. Tax-exempt audit data (FY16 to FY25) The chart below shows the year-over-year increase (or decrease) in IRS examinations of tax-exempt organizations from…More

In a June 9 opinion, the Tax Court held that a married couple were not engaged in horse breeding and training activities for profit and sustained the IRS’s disallowance of the taxpayers claimed loss deductions for three tax years.  The opinion is a helpful reminder to taxpayers and their tax advisors that substantiating profit motive is crucial when dealing with horse-related activities that could be considered a hobby rather than a business. In Schumacher v. Commissioner, T.C. Memo. 2026-47, the taxpayers…More

This is the final post in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act, a bipartisan legislative package introduced on February 26, 2026, by Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) to improve service and administration at the Internal Revenue Service.  Title X includes several administrative and technical provisions. For a general overview of the legislation, please refer to the Introduction and summaries of Titles I, II, III, IV, V, VI, VII, VIII, and…More

This is the ninth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act, a bipartisan legislative package introduced on February 26, 2026, by Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) to improve service and administration at the Internal Revenue Service.  Title IX proposes significant changes in order to reduce compliance burdens for small businesses and independent contractors.  For a general overview of the legislation, please…More

This is the eighth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced on February 26, 2026, by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  This alert addresses Title VIII of the proposed legislation, which focuses on Hostages. For a general overview of the legislation, please refer to the Introduction of this series and summaries…More