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

This is the seventh 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 VII of the proposed legislation, which focuses on Whistleblowers. For a general overview of the legislation, please refer to the Introduction of this series and summaries…More

This is the sixth 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 VI of the proposed legislation, which focuses on the IRS Independent Office of Appeals. For a general overview of the legislation, please refer to the Introduction…More

This article is the fifth in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  Our prior entries in the series are Title I (Tax Administration), Title II (American Citizens Abroad), Title III (Judicial Review), and Title IV (Taxpayer Advocate). This article examines the provisions of Title V of the TAS Act, titled “Tax Return Preparers.”  Title V…More

This is the fourth 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 IV of the proposed legislation, which focuses on the Office of the Taxpayer Advocate. For a general overview of the legislation, please refer to the Introduction…More

This article is the third in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”).  Our introduction to the series is here, our discussion of Title I is here, and our discussion of Title II is here. This article examines the provisions of Title III of the TAS Act, titled “Judicial Review.”  Title III expands the jurisdiction and…More