The Tax Adviser

Preparer’s intent to evade tax extends taxpayer’s limitation period

Stephanie Murrin underpaid her taxes from 1993 to 1999 because her tax preparer, Duane Howell, placed false or fraudulent entries on her tax returns with an intent to evade tax. Murrin did not intend ...
The Tax Adviser

Tax-advantaged ABLE accounts for disabled individuals

The Achieving a Better Life Experience (ABLE) Act of 2014 allows states to establish an ABLE program to assist persons with disabilities in building up tax – free (or in some cases tax – deferred) ...
The Tax Adviser

Notice 2025-27 provides interim guidance on corporate AMT

The notice provides an optional interim simplified method of determining whether a corporation is an applicable corporation for purposes of the corporate AMT and relief from the Sec. 6655 penalty for ...
The Tax Adviser

How a CPA and wealth adviser partnership can guide families through transition

A It’s more prevalent and often emerges earlier than many realize. According to the U.S. Census Bureau, the average age of widowhood in the United States is approximately 59, an age when many couples ...
The Tax Adviser

The ongoing fight against frivolous tax arguments

Taxpayers who make frivolous arguments in Tax Court risk the imposition of penalties by the court of up to $25,000.
The Tax Adviser

November 2025 - The Tax Adviser

Final regulations provide comprehensive guidance for tax reporting of transactions involving these increasingly common assets, and the IRS has granted transition relief in key areas.
The Tax Adviser

Tax Court applies limited partner functional test for self-employment income

In Soroban Capital Partners, the Tax Court analyzed the roles, responsibilities, and capital contributions of three limited partners in a limited partnership and determined that they were limited ...
The Tax Adviser

Two Tax Court rulings expose overvalued conservation easements

In the cases, the Tax Court determined the value of a conservation easement donated to charity using the comparable sales method instead of the discounted-cash-flow method.
The Tax Adviser

Digital asset transactions: Broker reporting, amount realized, and basis

In December 2022, Treasury and the IRS stated that they intended to implement the Infrastructure Act amendments to the Code by issuing new regulations and providing forms and instructions for broker ...
The Tax Adviser

Estate of McKelvey highlights potential tax pitfalls of variable prepaid forward contracts

Andrew McKelvey was the founder and former CEO of Monster Worldwide Inc. As such, he held a large amount of Monster stock with zero basis. The amount of stock to be delivered was determined by a ...
The Tax Adviser

Preserving the limitation statute for ERC claims

Under normal IRS procedures, filing a written protest contesting a disallowance gets a case in front of an IRS Appeals officer for consideration. After all, the IRS has disallowed the claim at this ...
The Tax Adviser

The role of REITs for foreign investors in US real estate

Editor: Robert Venables, CPA, J.D., LL.M. Foreign persons investing in U.S. real estate face unique tax complexities under the Internal Revenue Code. Navigating these complexities is crucial to ...