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Taxbyte

First-Time Penalty Abatement Is Being Replaced

2 min read
First Time Abate is going away. The new Automatic Exemption from Penalty grants relief without a call, but transition-year notices need attention.

Recent Taxbytes

When is a Settlement Partially Excludable? Tax Court Draws the Line (Joseph J. Zajac, III v. Comm., (TCM 2025-33))

3 min read
Joseph Zajac received a $35,001 settlement payment from the Town of Bolton related to claims

Failure to Pay Employment Taxes Gets Personal When Tax Court Rules Against Tax Professional (United States v. Tax and Bankruptcy Attorney, PLC, and Kenneth Keate., (US District Court for the District of Minnesota, NO. 0:22-CV-02928 (Nov. 27, 2024))

3 min read
In a case that should serve as a cautionary tale for all tax practitioners advising

Sixth Circuit Reverses Tax Court: IRA Distributions Taxable to Current Owner Even if IRS Took the Money (Lonnie W. Hubbard v. Comm., No. 24-1450, US Court of Appeals for the Sixth Circuit (March 19, 2025))

2 min read
In a significant decision, the Sixth Circuit reversed a Tax Court ruling that had treated

Noncustodial Parent Denied Dependency Despite Claiming One of Two Children for Years (Melissa Correll v. Comm., TCM 2025-31)

2 min read
When Melissa Correll claimed her 16-year-old son as a dependent on her 2021 return even

Government Secures $1.9 Million FBAR Penalty Judgment Against Estate (US v. Patricia Leeds, DC Idaho, No. 1:22-CV-00379 (Mar. 7, 2025))

2 min read
In a recent decision, the court granted summary judgment to the government in a case

When a Responsible Person’s Failure to Pay is “Willful” (Kristopher Dreyer v. United States, 9th Cir., No. 24-906, March 28, 2025)

4 min read
A nearly $188,000 personal tax liability struck board member Kristopher Dreyer when the Ninth Circuit

Safeguarding Independent Contractor Classifications: IRS Issues First Major Update to Section 530 Relief in 40 Years (Revenue Procedure 2025-10)

5 min read
Revenue Procedure 2025-10 provides updated guidance on Section 530 relief—the first update since 1985.

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