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CPE Resources – 2025

Our CPE resources list was designed to serve as a comprehensive repository of information presented in our online tax webinars and seminars. Each link corresponds to key topics covered in our continuing education sessions, offering quick access to critical updates, in-depth guides, expert insight and practical tools. This curated list allows tax professionals to revisit and apply the knowledge gained, ensuring they stay informed and equipped to address complex tax scenarios when needed. It’s a functional extension of our educational offerings, providing value beyond the live sessions.

Session Files (Custom Links)

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May 2025

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June 2025

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  • June 3, 2025 Casualty & Theft #1 — Intro (Individual Losses) (Webinar)

    • Handout (PDF Viewer) Session Handout
    • The Federal Disaster Relief Act of 2023 - major disaster declaration only
    • An exception to the rule limiting the deduction for personal casualty and theft losses to federal casualty losses applies where you have personal casualty gains to the extent the losses do not exceed the gains – more on this later
    • The IRS recently clarified in its 2024 Form 4684 instructions these disaster relief benefits only apply to certain presidentially declared disasters that began between December 28, 2019, and December 12, 2024 (inclusive of each date) and ended no later than January 11, 2025
    • Form 4797 - business
    • Pub. 584-B, Business Casualty, Disaster, and Theft Loss Workbook, is also available to help the business client make a list of damaged business or income-producing property and figure the loss
    • Progressive deterioration – Examples in Publication 547
    • Special procedure for corrosive drywall – Rev. Proc. 2010-36
    • Revenue Ruling 2009-9 - Losses from Ponzi-type Investment Schemes
    • In 2021 the Treasury Inspector General Report # 2021-40-045 noted that casualty loss deduction continue to be erroneously processed without valid FEMA Agency Number
    • A list of federally declared disasters and FEMA disaster declaration numbers is available at FEMA.gov/Disaster
    • Sec. 110009 of the bill -Extension of limitation on casualty loss deduction

  • June 5, 2025 Casualty & Theft #2 — Intro (Business Losses) (Webinar)

    • Handout (PDF Viewer) Session Handout
    • Generally, when the client has a casualty (or theft in 2026 and beyond – it is possible that some provisions of the TCJA will become permanent or extended beyond 2025), the client will need to file Form 4684 – Section B
    • Pub. 584-B, Business Casualty, Disaster, and Theft Loss Workbook, is also available to help the business client make a list of damaged business or income-producing property and figure the loss
    • Election under § 1033(a)(2) not to Recognize Gain from Compulsory or Involuntary Conversion
    • For a home you rented out or used for a business for which the client is not filing Schedule C (Form 1040), review § 280A(c)(5) to figure the deductible loss
    • If the business uses the simplified method to determine deductible expenses for business use of home for 2025, figure the casualty or theft loss for the home office in Section A instead of on Form 8829 and Section B
    • The property adjusted basis – any salvage value- any insurance reimbursements (Treas. Reg. § 1.165-7(b)(1)(ii))
    • Per § 280B demolition costs and the basis of any destroyed structures are generally capitalized and added to the basis of the land on which the demolished structure were located
    • IRS Notice 90-21 states that if a casualty loss damages or destroys a structure, and the structure is them demolished, the basis of the structure must be reduced by the casualty loss allowable per § 165 BEFORE the “loss sustained on the account of” the demolition is determined

  • June 10, 2025 Casualty & Theft #3 — Individual Case Studies (Webinar)

  • June 11, 2025 Casualty & Theft #4 — Business Case Studies (Webinar)

    • Handout (PDF Viewer) Session Handout
    • Treas. Regs. §1.469-2(d)(2)(xi) excludes from treatment as a passive activity deduction any “deduction for a loss from fire, storms, shipwreck, or another casualty, or from theft (as such terms are used in § 165(c)(3))
    • Consistent with the entity concept for the treatment of partnerships, §703(b) provides that the partnership shall make elections affecting how taxable income derived from a partnership is compute
    • The client would not be entitled to a deduction for a casualty loss because the § 179 deduction had reduced his basis to zero ($0.00)
    • If the insurance proceeds are less than the original cost, the gain would be ordinary income under § 1245
    • If the insurance proceeds are more than the original cost, the excess over the original cost would be a gain under § 1231, while the balance of the gain up to the original cost would be ordinary income under § 1245
    • Under Regs. § 1.263(a)-3(k)(1)(vi), Cole must capitalize as an improvement the $350,000 paid to the contractor to replace the roof structure because the roof structure constitutes a major component and a substantial structural part of the building unit of property
    • The Eight Circuit Court of Appeals, in Marshall Foods, identified the following factors that were relied on to determine that the policies insured against lost profits
    • The IRS has issued similar guidance in Treas. Regs §1.1033(a)-2(c)(8)

  • June 17, 2025 Casualty & Theft #5 — Odds & Ends (Webinar)

    • Handout (PDF Viewer) Session Handout
    • If the client’s home is destroyed by a disaster, they may still be able to utilize the § 121 exclusion to minimize or eliminate capital gains taxes on the deemed sale of the home
    • Then, use § 1033 to defer any remaining gain exceeding the exclusion limits by reinvesting the proceeds in replacement property
    • If part of a federal disaster loan was canceled under the Stafford Act, it is considered to be reimbursement for the loss
    • Review Depreciation Recapture in chapter 3 of Pub. 544 for more information about the recapture rule
    • This statement must show that the client is choosing to waive the carryback period under §172(b)

  • June 19, 2025 Form 1099-MISC and 1099-NEC for 2025 (Webinar)

  • June 24, 2025 Ethics: Part 1 (Webinar)

  • June 24, 2025 Ethics: Part 2 (Webinar)

    • Handout (PDF Viewer)Session Handout
    • Guidance regarding what actions non-practitioners may take in response to IRS inquiries is still necessary and authorized under 31 U.S.C. 330
    • Proposed regulations would clarify that ERPAs who passed the ERPA-SEE prior to February 12, 2016, remain authorized to practice before the IRS if they continue to pay the annual user fee described under 26 CFR 300.10(b) and complete the continuing education described in § 10.6(e).
    • Any future user fee will be calculated pursuant to the Independent Offices Appropriation Act of 1952 (31 U.S.C. 9701) and OMB Circular A-25, User Charges
    • Former IRS employees must apply for special enrollment in accordance with 31 CFR 10.4(d)..
    • Forms required for renewal may be obtained by sending a written request to the address specified by the Internal Revenue Service or from such other source as the Internal Revenue Service will publish in the Internal Revenue Bulletin (see 26 CFR 601.601(d)(2)(ii)( b)) and on the Internal Revenue Service website

  • June 26, 2025 Quarterly Tax Update 2025: Part 1 (Webinar)

    • Handout (PDF Viewer)Session Handout
    • The One Big Beautiful Bill Act (OBBBA, H.R. 1) "is the President’s number one priority
    • The Joint Committee on Taxation's analysis of the House-passed OBBBA shows several tax-related items as having "negligible revenue effect
    • https://www.crfb.org/blogs/breaking-down-one-big-beautiful-bill
    • The Joint Committee on Taxation (JCT) has released a document titled "General Explanation of Tax Legislation Passed by the 118th Congress and Enacted Into Law." (JCS-1-25)
    • Treasury and the IRS issued Notice 2025-33 extending and modifying the transition relief provided in Notice 2024-56 for brokers who are required to file Form 1099-DA, Digital Asset Proceeds From Broker Transactions to report certain digital asset sale and exchange transactions by customers
    • The Treasury Department’s congressional budget request for the 2026 fiscal year would reduce the IRS’s budget by more than 20% and rescind much of the remaining funding from the 2022 Inflation Reduction Act (IRA)
    • Revenue Procedure 2025-19 provides the 2026 inflation adjusted amounts for Health Savings Accounts (HSAs) as determined under § 223 and the maximum amount that may be made newly available for excepted benefit health reimbursement arrangements (HRAs) provided under § 54.9831-1(c)(3)(viii) of the Pension Excise Tax Regulations

July 2025

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  • July 8, 2025 Ministers/Amish/Mennonite Tax Issues

  • July 10, 2025 The Big Beautiful Bill: What Tax Pros Need to Know Now (Webinar)

    • Handout (PDF Viewer) Session Handout
    • §911 - Foreign Earned Income
    • §931 -  Income from sources within Guam, American Samoa, or the Northern Mariana Islands
    • §933 - income derived from sources within Puerto Rico
    • However, the deduction excludes tips earned in specified service trades or businesses under § 199A(d)(2) and is not available to highly compensated individuals
    • However, the deduction is not available to highly compensated employees or individuals whose earnings exceed the income threshold defined in § 414(q)(1)(B)(i)
    • Qualified Overtime Compensation - the term ‘qualified overtime compensation' means overtime compensation paid to an individual required under § 7 of the Fair Labor Standards Act of 1938 that is in excess of the regular rate (as used in such section) at which such individual is employed
    • •Married Individuals - If the taxpayer is a married individual (within the meaning of § 7703), this section shall apply only if  the taxpayer and the taxpayer's spouse file a joint return for the taxable year
    • §129(a)(2)(A) is amended by striking
    • § 21(a) is amended to read as follows..
    • The Excess Business Loss (EBL) rule applies to non-corporate taxpayers and is defined as the amount by which deductions (excluding net operating losses and §199A Qualified Business Income deductions) related to trades or businesses exceed income from such trade or business
    • In addition, OBBBA would increase the “aggregate gross asset” calculation under §1202(d) to $75 million from $50 million, that is also subject to an annual inflation adjustment
    • Domestic research costs are now fully deductible under new §174A
    • §163(j) - Reinstates the limitation on Earnings Before Interest, Taxes, Depreciation and Amortization (EBITDA) after Dec. 31, 2024
    • Line 4: Added checkboxes for Forms 4797 and 4684
    • Line 4: Added checkboxes to eliminate the write-ins for Forms 4361 and 4029 and a third checkbox and entry space for various write-ins
    • Form 8949 Sales and Dispositions of Capital Assets

  • July 15, 2025 S-Corporation Basis and Form 7203 (Webinar)

  • July 17, 2025 Update on Marijuana Tax Issues

    • Handout (PDF Viewer)Session Handout
    • In 1982 Congress enacted §280E, this limits what deductions are allowed when carrying on what consists to trafficking in a controlled substance
    • The final report issued stated that all deductions and credits for amounts paid or incurred in this venue would be disallowed - “Deductions and Credits” is determined by §162
    • §61(a) defines “gross income” broadly using examples of items that are includible in gross income
    • The Tax Court explained in Reading v. Commissioner, 70 T.C. 730, 733 (1978), “[t]he ‘cost of goods sold’ concept embraces expenditures necessary to acquire, construct or extract a physical product which is to be sold
    • In general, the taxpayer first determines gross income by subtracting COGS from gross receipts, and then determines taxable income by subtracting all ordinary and necessary business expenses (§162(a)) from gross income
    • In 1981, in Jeffrey Edmondson v. Commissioner, T.C. Memo. 1981-623 the court allowed an illegal business to recover the cost of the controlled substances obtained on consignment and to claim certain business deduction
    • Under the modified cash method described in Rev. Proc. 2001-10 and Rev. Proc. 2002-28, a reseller may account for merchandise as “inventories” or as “materials and supplies that are not incidental”
    • Recent Letter Ruling 201504011 – addresses the Uniform Capitalization Rules (UNICAP) under §263A and how a marijuana business should determine the COGS
    • The 1982 version of Regs. §Sec. 1.471-11(c)(2)(i) lists the following "indirect production costs which must enter into the computation of the amount of inventoriable costs, but only to the extent that the costs are necessary to the production of the inventory
    • Justice Department Announces Update to Marijuana Enforcement Policy – Cole Memo
    • HR 975, Respect State Marijuana Laws Act of 2017, amends the Controlled Substances Act to provide that the Act's regulatory controls and administrative, civil, and criminal penalties do not apply to a person who produces, possesses, distributes, dispenses, administers, or delivers marijuana in compliance with state laws
    • H.R. 1227 - Ending Federal Marijuana Prohibition Act of 2017 - Limits the application of federal laws to the distribution and consumption of marihuana, and for other purposes. Calls for the deregulation of marijuana. Prohibits inter-state shipping of marijuana
    • H.R. 1824 Responsibly Addressing the Marijuana Policy Gap Act of 2017: This bill would help bridge the current bifurcations between federal marijuana laws and state laws. It would remove federal criminal penalties and civil asset forfeitures for businesses that are following their state's cannabis laws but not federal law.
    • H.R. 715, Compassionate Access Act, provides for the rescheduling of marijuana, the medical use of marihuana in accordance with state law, and the exclusion of cannabidiol from the definition of marihuana, and for other purposes
    • H.R. 331 States’ Medical Marijuana Property Rights Act, amends the Controlled Substances Act so as to exempt real property from civil forfeiture due to medical marijuana-related conduct that is authorized by state law
    • H.R. 714, LUMMA (Legitimate Use of Medicinal Marihuana Act) - provides for the legitimate use of medicinal marihuana in accordance with the laws of the various states
    • S. 780 and H.R. 1824- Responsibly Addressing the Marijuana Policy Gap Act - Amends the Controlled Substances Act to reduce the gap between Federal and State marijuana policy, and for other purposes
    • S. 775 and H.R. 1823 - Marijuana Revenue and Regulation Act: This measure would de schedule, tax, and regulate cannabis. This bill reintroduces the idea of taxing and regulating marijuana like alcohol, with escalating annual excise tax rates that could top out at 25% of the sales price of the product
    • H.R. 1952 Better Drive Act would amend title 23, United States Code, with respect to the revocation or suspension of drivers’ licenses of individuals convicted of drug offenses, and for other purposes
    • H.R.1013 - Regulate Marijuana Like Alcohol Act - Directs the Attorney General to issue a final order that removes marijuana in any form from all schedules of controlled substances under the Controlled Substances Act.

  • July 22, 2025 Form 706 / 709 Unlock — Estate Planning and Portability (Webinar)

    • Handout (PDF Viewer)Session Handout
    • Form 706
    • Form 709
    • Often involved significant outside legal or tax professional expense and an IRS user fee ($38,000 in calendar year 2022 (Rev Proc 2022-1, Appendix A, §A(4), 2022-1 I.R.B. 1.))
    • Form 706 - Review of Form
    • Treas Regs §20.2010-2(a)(7)(ii)(A)
    • Revenue Procedure 2022-32 - Review of Form
    • Filed Pursuant to Rev. Proc. 2022-32 to Elect Portability under IRC §2010(c)(5)(A)
    • The property that passes will be subject to estate tax as distributions are made (IRC §2056A)
    • The expenses associated with the Form 706 are deducted on Form 1041 (via an election under IRC §642(g))
    • Form 706 - Example PDF
    • Supersedes Revenue Procedure 2017-3 (2017-26 I.R.B. 1282)
    • The executor must not be required to file an estate tax return under IRC §6018(a) (e.g., the decedent’s gross estate is $50,000,000 – Form 706 must be filed)
    • Under Section 3.04 … An executor may still make a request for an extension of time to make the portability election by requesting a letter ruling (subject to a user fee) under the provisions of Treas Regs §301.9100-3
    • The timing of the claim for credit or refund might be outside the period of limitations under IRC §6511(a)

  • July 24, 2025 Charitable Contributions Compliance (Webinar)

    • Handout (PDF Viewer)Session Handout
    • Note: Digital assets are not publicly traded securities for the purposes of Form 8283, unless the digital asset is publicly traded stock or indebtedness
    • Review Pub. 597, Information on the United States–Canada Income Tax Treaty, for information on how to figure the deduction
    • The 50 % limitation applies to:
      • all public charities (code PC)
      • all private operating foundations (code POF)
      • certain private foundations that distribute the contributions they receive to public charities and private operating foundations within 2-1/2 months following the year of receipt, and
      • certain private foundations the contributions to which are pooled in a common fund and the income and corpus of which are paid to public charities
    • The 30 % limitation applies to private foundations (code PF), other than those previously mentioned that qualify for a 50 % limitation, and to other organizations described in § 170(c) that do not qualify for the 50%  limitation, such as domestic fraternal societies (code LODGE)
    • Grantors and contributors may continue to rely on the Pub.78 data contained in Tax Exempt Organization Searchto the same extent provided for in Revenue Procedure 2011-33
    • Review Revenue Procedure 89-23 
    • The client must attach to their return Copy B of the Form 1098-C, Contributions of Motor Vehicles, Boats, and Airplanes, (or other statement containing the same information as Form 1098-C) received from the organization
    • Review Pub. 551 if the client contributes property that:
      • They received as a gift or inheritance
      • Used in a trade, business, or activity conducted for profit or
      • Claimed a casualty loss deduction

  • July 29, 2025 Ethics: Part 3 (Webinar)

  • July 29, 2025 Ethics: Part 4 (Webinar)

  • July 30, 2025 Employee vs. Independent Contractor — Strategies to Get It Right & Avoid Penalties (Webinar)

August 2025

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  • August 6, 2025 Estates & Trusts (Webinar)

  • August 7, 2025 Ethics Part 1 (Webinar)

  • August 7, 2025 Ethics Part 2 (Webinar)

    • Handout (PDF Viewer)Session Handout
    • Guidance regarding what actions non-practitioners may take in response to IRS inquiries is still necessary and authorized under 31 U.S.C. 330
    • Proposed regulations would clarify that ERPAs who passed the ERPA-SEE prior to February 12, 2016, remain authorized to practice before the IRS if they continue to pay the annual user fee described under 26 CFR 300.10(b) and complete the continuing education described in § 10.6(e).
    • Any future user fee will be calculated pursuant to the Independent Offices Appropriation Act of 1952 (31 U.S.C. 9701) and OMB Circular A-25, User Charges
    • Former IRS employees must apply for special enrollment in accordance with 31 CFR 10.4(d)..
    • Forms required for renewal may be obtained by sending a written request to the address specified by the Internal Revenue Service or from such other source as the Internal Revenue Service will publish in the Internal Revenue Bulletin (see 26 CFR 601.601(d)(2)(ii)( b)) and on the Internal Revenue Service website

  • August 12, 2025 There is a Form for That (Webinar)

    • Handout (PDF Viewer)Session Handout
    • Form 1040 LEP
    • If you choose not to amend that return, any unused basis from the repayment should be carried forward and reported the next time you file Form 8606 for a Roth IRA distribution
    • After the EIC, CTC/RCTC/ACTC/ODC, or AOTC was reduced or disallowed in an earlier year (a) you filed Form 8862 (or other documents) and the credit was then allowed, and (b) the credit has not been reduced or disallowed again for any reason other than a math or clerical error
    • Form 8949 and Schedule D has been modified for 2025 to reflect these changes
    • Digital Token Identification Foundation (DTIF)
    • Line 4: Added checkboxes to eliminate the write-ins for Forms 4361 and 4029 and a third checkbox and entry space for various write-ins
    • Form 15397  Application for Extension of Time to Furnish Recipient Statements
    • Form 4852 -  Substitute for Form W-2, Wage and Tax Statement, or Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc.
    • The client must complete a separate Form 3911 for each refund for which you are requesting information
    • If the refund check was cashed, the Bureau of the Fiscal Service (BFS) will provide the client with a claim package that includes a copy of the cashed check
    • Form 12203 - Request for Appeals Review – Small Case Request
    • Note: If the client disagrees with a lien, levy, seizure or a denial, modification or termination of an installment agreement, review Publication 1660, Collection Appeal Rights PDF, for information on filing the protest
    • Form 843 - Claim for Refund and Request for Abatement
    • Form 8822 – Change of Address
    • Form 8822-B - Business Change of address or responsible party
    • Form 4506 – Request for a Copy of a Tax Return
    • Form 4506-T – Request for a Transcript of a Tax Return
    • Form 4506-B – Request for a Copy of an Exempt Organization IRS Application or Letter
    • Form 1310 Statement  of Person Claiming a Refund Due to Deceased Taxpayer

  • August 13, 2025 Tax-exempt Organizations (Webinar)

  • August 14, 2025 IRS “B” and “C” Notices (Webinar)

    • Handout (PDF Viewer)Session Handout
    • W-8BEN - Form W-8BEN, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding
    • W-8BEN-E - Form W-8BEN-E, Certificate of Entities Status of Beneficial Owner for United States Tax Withholding (Entities)
    • W-8ECI - Form W-8ECI, Certificate of Foreign Person’s Claim for Exemption From Withholding on Income Effectively Connected With the Conduct of a Trade or Business in the United States
    • W-8EXP - Certificate of Foreign Government or Other Foreign Organization for United States Tax Withholding
    • W-8IMY - Certificate of Foreign Intermediary, Foreign Flow-Through Entity, or Certain U.S. Branches for United States Tax Withholding
    • The "B" Backup Withholding Program, under the authority of Treasury Regulation § 31.3406(d)-5 and § 3406(a)(1)(b), provides a CP2100 or CP2100A notice to payers (a financial institution, business or person) who file certain information returns with incorrect taxpayer identification numbers (TINs) to begin backup withholding
    • Gambling winnings reportable on Form W-2G, Certain Gambling Winnings, unless subject to regular gambling withholding
    • After the submission of Form 1099 information returns, the IRS will send the payor a CP2100 or a CP2100A Notice, and a listing of incorrect Name/TIN(s) reported on those forms
    • Requirement one is also met if the entities name indicates that it is an entity listed as a corporation under IRS Regulations, § 301.7701-2(b)(8)(i)

  • August 19, 2025 Impact on Expiring Tax Provisions – TCJA (Webinar)

  • August 21, 2025 Quarterly Tax Update 2025: Part 2 (Webinar)

  • August 26, 2025 Farm Rentals (Webinar)

  • August 27, 2025 Residential Complications (Webinar)

September 2025

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  • September 2, 2025 IRS Streamlined Procedures & Nonwillful Certification (Webinar)

    • Handout (PDF Viewer)Session Handout
    • IRM Procedural Update dated August 13, 2014, - A recent sheds some light on what type of submissions might be ripe for examination under the streamlined procedures.
    • Form 3520 - Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts
    • Form 926 - Return by a U.S. Transferor of Property to a Foreign Corporation
    • Form 3520-A - Information Return of Foreign Trust With a U.S. Owner
    • Form 5471 - Information Return of U.S. Persons with Respect to Certain Foreign Corporations
    • Form 5472 - Information Return of a 25% Foreign- Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business
    • Form 8865 - Return of U.S. Persons With Respect to Certain Foreign Partnerships
    • Offshore Voluntary Disclosure Program - Taxpayers who think that they can outsmart the fox by seeking shelter in the OVDP bunker in the event that the IRS rejects their non-willful certification are sadly mistaken. Why? Once a taxpayer makes a submission under the streamlined procedures, it is too late to apply to its sister program, the .
    • IRC section 7701(b)(3) - Those satisfying the substantial presence test of .
    • IRC section 162(a)(2) - For purposes of IRC section 911, “tax home” has the same definition as it does under (relating to traveling expenses while away from home). Under Treas. Reg. § 1.911-2(b), an individual’s tax home is considered to be located either:
    • Treas. Reg. § 1.911-2(b) - For purposes of IRC section 911, “tax home” has the same definition as it does under IRC section 162(a)(2) (relating to traveling expenses while away from home). Under , an individual’s tax home is considered to be located either:
    • Updated IRS Streamlined Filing Program: Snowbirds Beware: - The issue was best framed by Paul Barba in his blog,
    • FinCEN and Form 114 - Have failed to report gross income from a foreign financial asset and pay tax as required by law. Even if the taxpayer reported gross income from the foreign asset and paid all taxes relating to that asset, this element is satisfied if the taxpayer failed to file an FBAR ( Form 114) and/or one or more international information returns with respect to the foreign financial asset. By information returns, the IRS is referring to Forms 3520, 3520-A, 5471, 5472, 8938, 926, and 8621); and
    • Form 8938 - A: No. Any asset that is not the kind of asset reportable on either an FBAR or need not be included in the penalty base for the streamlined domestic offshore procedures.

  • September 3, 2025 Tax Research Strategies (Webinar)

  • September 9, 2025 Amended vs Superseded Returns (Webinar)

    • Handout (PDF Viewer)Session Handout
    • IRC §6501(e) - Does overstating basis constitute an “omission from gross income” for purposes of analyzing the statute of limitations in ?
    • Colony, Inc. v. Commissioner - Following , 357 U. S. 28 (1958), the counts have held that the provision does not apply to an overstatement of basis.
    • , 357 U. S. 28 (1958) - Following Colony, Inc. v. Commissioner, the counts have held that the provision does not apply to an overstatement of basis.
    • § 7201 - It is also described as a felony in.
    • Internal Revenue Manual 25.6.1.9.4.5 - Per the , “the assessment date” will start the period for the statute of limitations for collection per § 6502(a)(1).
    • § 6020(a) - From the same section of the Internal Revenue Manual, “If the client signs a SFR return prepared from income information received from the client, it becomes the client’s return per and starts the assessment period of limitations”.
    • § 6502(a)(1) - Collection after assessment - Where the assessment of any tax imposed by this title has been made within the period of limitation properly applicable thereto, such tax may be collected by levy or by a proceeding in court, but only if the levy is made or the proceeding begun.
    • §6343 - B) there is a release of levy under after such 10-year period, prior to the expiration of any period for collection agreed upon in writing by the Secretary and the taxpayer before such release.
    • IRS: Where to File — Amended Returns
    • Form 1040-X, Amended U.S Individual Income Tax Return - In one of the latest improvement for clients, the Internal Revenue Service announced February 9, 2023, that people electronically filing their , will for the first time be able to select direct deposit for any resulting refund.
    • TC 150 - Returns filed, and tax liability assessed.
    • IRM 3.11.6.3.3.2
    • CCA 202026002 - Recently a has challenged that assumption by concluding that a superseding return does not, in fact, replace an original return for purposes of determining the statutes of limitation for assessments and for the filing of refund claims.
    • Zellerbach - Paper Co. v. Helvering, 293 U.S. 172 (1934).
    • National Paper Products Co. v. - Helvering, 293 U.S. 183 (1934).
    • IRM 21. 6. 7. 4. 10 - Filing a superseded return is like filing an original return except in red at top of Form 1040 write, “Superseded Return ”.
    • www.irs.gov - Other Issues - Document Locator Number (DLN).
    • IRM 3.10.73 - Complete information can be found in for Non-remittance Documents.
    • Julian Date Converter - Used for the 6th, 7th and 8th digits in the Document Locator Number (DLN) to identify the date of the return given as a Julian Date.

  • September 11, 2025 Employment Taxes & Trust Fund Recovery Penalty (Webinar)

    • Handout (PDF Viewer)Session Handout
    • TFRP - Prior to being turned over to the government, the employer holds the funds and can use them for any purpose whatsoever, although the person or persons directing their use for purposes other than payment of the trust fund tax can be liable for this or even a collateral criminal penalty (§ 7202).
    • § 7202 - Prior to being turned over to the government, the employer holds the funds and can use them for any purpose whatsoever, although the person or persons directing their use for purposes other than payment of the trust fund tax can be liable for this TFRP or even a collateral criminal penalty ().
    • § 6672 - imposes civil liability upon certain persons other than the employer for unpaid trust fund taxes.
    • IRS Policy Statement P-5-60 - sheds some light on who bears the “distinction” of being a responsible person
    • § 6671(a) - The TFRP is an “assessable penalty” under .

  • September 17, 19, 23, 25 & October 1, 2025 [Seminar] Fall Topical Income Tax Update

    Sep 17 Sep 19 Sep 23 Sep 25 Oct 1

    Session Handouts

    Additional Materials

    2025 Treasury/IRS and OMB Draft Forms

  • Part 1 - TCJA Updates & OBBBA Changes

    • https://www.congress.gov/bill/119th-congress/house-bill/1/text
    • § 469(h) - New minimum $400 deduction for taxpayers with at least $1,000 of QBI {Active Trade or Business } ..
    • §62(a)(D) - Allows for unreimbursed educator expenses to be deducted as miscellaneous itemized deduction, however, $300 still deducted above the line ..
    • §162 - Professional gamblers ordinary & necessary business expenses are treated as wagering losses & deductions allowed to extent of gains ..
    • §199A - Trade or Business cannot be SSTB (defined by .. )
    • §224(d) - Such term shall not include any qualified tip ..
    • IRC §§ 267(b) - Not allowed regarding Related Parties under or 707(b)(1) to the taxpayer ..
    • IRC §45F
    • IRC §707(a)(2)(B) - is self-executing
    • § 6501(b)(2) - The date on which such return is treated as filed under , or ..
    • §24(h)(7) - SSN shall have the meaning given such term in ..
    • §448c - Small Businesses (IRC) eligible to elect to claim deduction retroactively to 2022
    • IRC § 163(j)(9)(C) - Exception floor plan financing now applies to certain trailers and campers ..
    • IRC §179(d) - Acquisition of such property meets requirements of paragraphs (2)(A), (2)(B), (2)(C), and (3) of {definition and special rules}

  • Part 2 - Centralized Partnership Audit Regime

    • § 6221(b) - allows partnership to elect out for tax year if meeting eligibility requirements
    • IRM 4.31.9.10 (01-24-2024)
    • Regs. § 601.501 - through 601.509
    • Bipartisan Budget Act (BBA) - Roadmap for Taxpayers (PDF)
    • IRC § 6225 - to the rescue
    • § 6226 - “push out” election requirements
    • 6227(b)(2) - Partnership may elect to push out adjustments under § and Regs. § 301.6227-2(c) resulting in an ‘IU’ to its reviewed-year partners
    • Regs. § 301.6227-2(c) - Partnership may elect to push out adjustments under § 6227(b)(2) and resulting in an ‘IU’ to its reviewed-year partners
    • Form 1065 - reports your partnership's business performance to the IRS each tax year. Partnerships don't generally pay taxes, but use Form 1065 to prepare Schedule K-1s (and Schedule K-3s, if needed) to pass through income and losses to partners.
    • Form 8986 - Individuals furnished with generally must pay any tax due with respect to AAR adjustment
    • Form 8082 - Notice of Inconsistent Treatment or Administrative Adjustment Request (AAR)
    • Form 8985 - used by partnership to summarize and transmit Forms 8986
    • Form 8978 - Partner’s Additional Reporting Year Tax, and its Schedule A calculates additional tax due or overpayment

  • Part 3 - Required Minimum Distributions & Penalty Updates

    • IRC §170(f) - Charitable documentation requirements …
    • IRC §170(b)(1)(A) - The charity must be an organization described in , other than an organization described in IRC §509(a)(3) or a donor advised fund as defined in IRC §4966(d)(2) ..
    • IRC §509(a)(3) - The charity must be an organization described in IRC §170(b)(1)(A), other than an organization described in or a donor advised fund as defined in IRC §4966(d)(2) ..
    • IRC §4966(d)(2) - The charity must be an organization described in IRC §170(b)(1)(A), other than an organization described in IRC §509(a)(3) or a donor advised fund as defined in ..
    • Form 1099-R - Tax reporting – reporting ..
    • IRC §408(d)(8) - Code Y will be used to designate Qualified charitable distribution (QCD) claimed by a taxpayer under in Box 7 of Form 1099-R ..
    • Act §307 - Congress says no! states that a distribution to a CRUT or CRAT will only count as a QCD if the trust is funded exclusively by qualified charitable distributions ..
    • IRC §408 - The trustee or custodian must be a bank or another person who demonstrates, to the satisfaction of the Secretary, that the manner in which they will administer the account will be consistent with the requirements of this section (reference to the Internal Revenue Code for IRAs … ) ..
    • IRC §401 - Distribution Rules ..
    • Boggs vs Boggs - Retirement Equity Act and ..
    • Kennedy vs Plan Administrator
    • Egelhoff vs Egelhoff
    • IRC §401(a)(9) - Designated Beneficiary – person or trust that qualifies as a designated beneficiary under the Treas Regs for . A qualified designated beneficiary is allowed to utilize the life expectancy of a beneficiary. Term defined in Treas. Reg. §1.401(a)(9)-4, Q&A 1 ..
    • IRC §72(m)(7) - Under – an individual shall be disabled if they are unable to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or to be of long-continued and indefinite duration ..
    • IRC §7702B(c)(2) - Under - an individual who has been certified by a licensed health care provider / practitioner as – ..
    • IRC §72(t) - The distribution is subject to federal and state, if applicable, income taxes and quite possibility subject to the additional tax ..
    • IRC §4974(d) - allows the IRS to waive the excise tax if the taxpayer can show the shortfall was due to reasonable error and that reasonable steps are being taken to remedy it ..
    • IRC §§401(a)(9) - The "minimum required distribution" is the minimum amount required to be distributed during a taxable year under , 403(b)(10), 408(a)(6), 408(b)(3), or 457(d)(2), as determined under regulations ..
    • 403(b)(10) - The "minimum required distribution" is the minimum amount required to be distributed during a taxable year under IRC §§401(a)(9), , 408(a)(6), 408(b)(3), or 457(d)(2), as determined under regulations ..
    • 408(a)(6) - The "minimum required distribution" is the minimum amount required to be distributed during a taxable year under IRC §§401(a)(9), 403(b)(10), , 408(b)(3), or 457(d)(2), as determined under regulations ..
    • Form 5329 - Summary - SECURE 2.0 reduced the RMD excise tax from 50% to 25% (and to 10% if corrected within the correction window), provided a clear correction process, and the IRS has granted transition relief for certain missed RMDs in 2021–2024. Taxpayers should use to report and, if appropriate, request a waiver of the excise tax ..

  • Part 4 - Estates & Gift Tax Updates

    • Form 709 - Used by individuals who gift above the annual gift limit or have generation-skipping transfer tax. Tracking is done over multiple years and returns only need to be filed for years where excess gifting has been done. Joint filers should file separate returns if gift-splitting is done but report the totals on each return.
    • Form 1041 - Filed for a trust or estate by a fiduciary to report income, deductions, gains or losses, current or future distributions to beneficiaries, employment taxes or NIIT. A trust may be created inter vivos (while someone is alive) or testamentary (via a will at death). One major difference between Form 1040 & 1041 is that Form 1041 allows an Income Distribution Deduction.
    • Form 706
    • Section 2032 rules - Alternate Values are allowed per the or Special-Use rules under Section 2032A
    • Section 2032A - Alternate Values are allowed per the Section 2032 rules or Special-Use rules under
    • T.C. Memo 2025-76 - The IRS reviews these valuations for fair reporting, as well as, timely filing of DSUE returns (See , Estate of Billy S. Rowland)
    • Form 7004 extension allows a 5 1/2-month grace period
    • Form 8855 must be filed to take 645 election
    • Qualified Terminable Interest Property - To make the election (QTIP)

  • Part 5 - Pass-Through Entity Taxes & 2025 Updates

    • IRS Notice 2020-75
    • §164(a)(1)&(2) - Taxes incurred with carrying on a trade or business
    • SITPs - Language within 2020-75 suggests that the deduction need not be related to a trade or business
    • IRC § 111 - Recovery of tax benefit items under § 111
    • IRC § 212 - Deemed an IRC § 164 deduction vs. an expense (not automatically nondeductible just because it is from a § 212 activity)

  • Part 6 - Ethics

    • Professional Conduct 1.3 - Review, ABA Model Rule of , Diligence
    • Form 2848 - Discussing with clients whether to authorize additional practitioners to represent the client or receive information on the client’s behalf via a or Form 8821, Tax Information Authorization, respectively, to avoid an interruption in representation before the IRS
    • Form 8821, Tax Information Authorization - Discussing with clients whether to authorize additional practitioners to represent the client or receive information on the client’s behalf via a Form 2848 or , respectively, to avoid an interruption in representation before the IRS
    • § 7216 - Check the Rules of Conduct for your licensing – does it provide additional guidance over and above Circular 230 and
    • § 6103 - Review § 7216 and in the event of a sale situation
    • Reg. § 301.7216-2(n) - specifically includes wording related to the transfer of a list of items relating the client's information without consent
    • National Account Profile - The RPO checks the (NAP) monthly and changes PTIN statuses to “deceased” as appropriate
    • IRC Section 708(b)(1)(B) - Form a new partnership after terminating one under
    • Treas. Reg. 301.6109-1 - Change ownership of 50% or more of the partnership within 12 months (See terminated partnerships under )
    • Section 7216 information center - Review for more information
    • Reg. § 300.6103(n)(1) - Under – Disclosure of returns and return information in connection with written contracts and agreements for the acquisition of property or services for tax administration purposes is allowed under certain circumstances
    • Publication 4557 - For general guidance on safeguarding taxpayer information, see IRS , Safeguarding Taxpayer Data (A Guide for Your Business)
    • Professional Conduct 1.6 - Safeguarding client information is also part of an attorney-practitioner’s (and law firm’s) ongoing professional responsibility. ABA Model Rule of , Confidentiality of Information. Likewise, there may be comparable protections at the state level that CPAs must comply with, as there are in California, for example
    • Cal. Code Regs. tit. 16, § 54.1 - “No confidential information obtained by a licensee, in his or her professional capacity, concerning a client or a prospective client shall be disclosed by the licensee without the written permission of the client or prospective client, except for the following: [enumerating several exceptions, including:
    • Cf. ABA Formal 92-369, n. 8
    • Treas. Reg. § 301.7216-1(b)(3) - The prohibition includes any violation of § 6713 or § 7216, which are civil and criminal penalties for unauthorized use or disclosure of income “tax return information” (defined in )
    • Circular 230 - Maintaining Professional Standards: The sale should not compromise the professional standards of either the seller or the buyer, including adherence to relevant codes of ethics and professional conduct, such as
    • Regs. Sec. 1.6695-2(b)(4)(ii) - Specific record-retention requirements encompassing the five types of records to be maintained and the length of time those records must be kept (generally, three years) are detailed in
    • FAQs to SSTS No. 7 - As an example, while the AICPA Statement on Standards for Tax Services (SSTS) No. 7, Form and Content of Advice to Taxpayers, does not include a discussion on record retention, the do state: “Where the taxpayer only requests oral advice, it is recommended that the member contemporaneously document the advice in written form in the taxpayer’s file”
    • § 6501(e)(1)(A) (ii) - For example, under , the statute of limitation is doubled to six years if more than $5,000 of foreign income is not reported
    • § 6511(d)(1) - The IRS can look back seven years relative to a loss on worthless securities or a bad debt deduction ..

  • Part 7 - Online Account Setup Basics & Ask the Expert

October 2025

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  • October 1, 2025 [Seminar] Fall Topical Income Tax Update (see September group)

  • October 7, 2025 Ethics: Part 3 (Webinar)

  • October 7, 2025 Ethics: Part 4 (Webinar)

  • October 9, 2025Charitable Gifting (Webinar)

  • October 15, 2025IRS Collection Due Process Procedures (Webinar)

    • Handout (PDF Viewer)Session Handout
    • Form 870 - TP will also be considered to have had a previous opportunity to contest if he waives the right to a notice of deficiency on or Form 4549
    • Form 4549 - TP will also be considered to have had a previous opportunity to contest if he waives the right to a notice of deficiency on Form 870 or
    • § 6330 - Analysis: The plain language of entitles TPs to an opportunity to establish that they erred in their self-assessment b/c the IRS had n/ issued a notice of deficiency (which, of course, they were n/ required to do b/c there was no tax deficiency) and TPs did n/ have an opportunity to dispute their tax liability. This holding advances the policies of these sections and is consistent w/ Congressional intent that the IRS should collect the correct amount of tax
    • 3598 - Example: If examination division completed an audit and issued a statutory notice of deficiency and TP failed to petition the U.S. Tax Court, the tax on the notice will be assessed. TP can follow procedures in to dispute the assessed tax liability (audit reconsideration process).
    • § 6673 - allows the court to penalize TP up to $25K, it if appears that TP has instituted a proceeding primarily for delay or when TP advances frivolous or groundless positions
    • § 6702(b) - To discourage TPs from requesting CDP hearings in the first place when they don’t have legitimate concerns, imposes a $5K penalty on any person who submits a “specified frivolous submission”
    • Form 12257 - If TP and Appeals employee reach agreement about case, TP will be asked to sign an agreement form –
    • Wagner - Facts from : TPs filed a CDP petition in Tax Court, but sought to have the case dismissed w/o prejudice in order to pursue litigation in district court regarding net operating losses that TPs sought to carry back to the year at issue in Tax Court
    • Robinette - Rule from (Eighth Circuit): Judicial review of the procedural aspects of a CDP determination is limited to the administrative record. However, if the record does n/ adequately describe the hearing process or there is a dispute over what happened during the process, the reviewing court is permitted to supplement the administrative record w/ other evidence outside the record
    • Lunsford - Rule in : As w/ a notice of deficiency, in determining its jurisdiction, the Tax Court will n/ “look behind” the notice of determination to determine whether it was validly issued. The Tax Court will examine only the notice of deficiency, itself to determine whether it is valid for jurisdictional purposes

  • October 21, 2025From Summonses to International Evidence Gathering Techniques — How the IRS Gathers Evidence (Webinar)

    • Handout (PDF Viewer)Session Handout
    • § 7602(a) - IRC : Empowers the IRS to production of documents and testimony (link)
    • IRC § 7609 - Generally, the IRS must notify taxpayers being examined of the issuance of summonses to third parties (link)
    • U.S. v. Clarke - The summons was issued in bad faith (site)
    • Tiffany Fine Arts case - A summons may be issued for a dual purpose: that is, it may be used in order to obtain information relating to an identified taxpayer, as well as an unidentified taxpayer (site)
    • U.S. v. Gertner - Example of case where the government went too far (site)
    • U.S. v. Lefkowitz - search warrants require the approval of the AUSA in charge (site)

  • October 22, 2025 Form 1041 Compliance Review and Planning: Part 1 (Webinar)

  • October 28, 2025Form 1041 Compliance Review and Planning: Part 2 (Webinar)

    • Handout (PDF Viewer)Session Handout
    • IRC § 643
    • 65 Day Rule (IRC §663(b))
    • IRC §691(c) Deduction
    • IRC §645 Election
    • Charitable Deduction under IRC §642(c)
    • Pecuniary Bequests to Charity and CCA 200644020
    • IRC §4947(a)(1) Trusts – all remaining interest in income and principal go to qualified charities and grantor was allowed a charitable deduction
    • IRC §4947(a)(2) Trusts – not all remaining interest in income and principal goes to qualified charities and grantor was allowed a deduction
    • Pursuant to IRC §642(g) and Regulation §1.642(g)-1, the taxpayer elects to deduct the following expenses on Form 1041 for the year ending February 28, 2025. Such expenses have not been claimed under IRC Sec. 2053 on Form 706 and further, taxpayer hereby waives the right to deduct the expenses at any time for estate tax purposes under IRC §2053.
    • Pursuant to IRC §642(g) and Regulation §1.642(g)-1, the taxpayer elects to deduct the following expenses on Form 1041 for the year ending February 28, 2025. Such expenses have not been claimed under IRC Sec. 2053 on Form 706 and further, taxpayer hereby waives the right to deduct the expenses at any time for estate tax purposes under IRC §2053.
    • U.S. Tax Court case … Frank Aragona Trust v. Commissioner
    • IRC §664 – Charitable Remainder Trusts
    • Additional contributions may not be made to a CRAT after its formation (Treas Regs §1.664-2(b))
    • Low IRC §7520 rates limit the tax planning effectiveness
    • Form 1041 – Compliance … Part 2 … Form 5227 – Split-Interest Trust Information Return
    • Self-dealing (IRC §4941)
    • Taxes on excess business holdings (IRC §4943)
    • Taxes on investments that jeopardize charitable purposes (IRC §4944)
    • Taxes on taxable expenditures (IRC §4945) and political expenditures (IRC §4955)

  • October 30, 2025Turning Theory into Practice — Estates and Trusts (Webinar)

    • Handout (PDF Viewer)Session Handout
    • IRC §671 through IRC §679 note that the Trust is ignored for tax purposes
    • Trust is valid under state law (Treas Regs §1.401(a)(9)-4(f)(2)(i))
    • Results – Mel retained the right to income of trust for life. He is treated as the owner of the income portion of the trusts (IRC §677). Mel will include $25,000 of dividend income on his tax return. Unfortunately, under TCJA, the $2,500 of expenses will not be deductible (miscellaneous itemized deductions are no longer available, after 2017).
    • For Grantor Trust purposes (Subpart E of the IRC), income means income for tax purposes (i.e., distributable net income) and ordinary income means fiduciary accounting income (Treas. Regs. §1.671-2(b))
    • IRS ruled that the receipt of the entire corpus of a trust in exchange for an individual’s unsecured promissory note constituted an indirect borrowing of the trust corpus which caused the individual to be the owner of the entire trust (IRC §675(3)).
    • Both executor and trustees of all revocable trusts making the election must sign on by filing Form 8855 by the due date including extension for filing the estate’s first income tax return
    • Note: Treasury and Internal Revenue Service are planning to release Treasury Regulations under IRC §645 soon
    • The amount of Grantor’s retained annuity interest is calculated using a modified government interest rate – the IRC §7520 rate
    • Treas Regs §25.2702-3(b)(1) allows the annuity payment to increase by up to 20% per year

November 2025

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December 2025

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