Articles on Federal Taxation

An Appearance of Impropriety in Administrative Hearings By Alan Rhine Federal Taxation, November 2025 This article explores the role of administrative law judges and analyzes the possibility of bias or the appearance of impropriety under the Illinois Code of Judicial Conduct of 2023. 
One Big Beautiful Bill Act: Considerations for Charitable Planning By Philip M. Purcell Federal Taxation, November 2025 A look at provisions of the One Big Beautiful Bill Act (OBBBA) and how this Act impacts income tax, estate tax, and other miscellaneous changes. 
Tax Court Takes a Strict Stance on Procedural Deadlines Under the BBA Partnership Audit Rules By Sandra D. Mertens & Grace Symington Federal Taxation, November 2025 Recent Tax Court decisions, including JM Assets and Bayou Serpent, demonstrate strict enforcement of procedural deadlines. This strict adherence reinforces the importance of diligence and punctuality, safeguarding the integrity of the judicial process by emphasizing the necessity of complying with procedural requirements. 
Why I Seek Out Rooms Without Lawyers—And Why You Might Too By Ricardo Santiago Federal Taxation, November 2025 Learn about the benefits of networking outside of your usual professional circles and challenge yourself to network with non-attorneys to grow your practice. 
2025 Illinois Tax Amnesty Programs Offer Opportunities for Penalty and Interest Relief to Taxpayers By Sandra D. Mertens & Grace Symington Federal Taxation, October 2025 Familiarize yourself with the 2 amnesty programs that will take effect in the fall of 2025 as a direct result of House Bill 2755, signed by Governor Pritker on June 16, 2025. 
AI and Law: An Opportunity to Improve Legal Practice By Damien Riehl Federal Taxation, October 2025 Recent exponential leaps in advanced large language models have presented both opportunities and challenges that have the capacity to reshape the legal landscape.
Recent Changes to the IRS Office of Appeals By Sandra D. Mertens & Grace Symington Federal Taxation, October 2025 The Internal Revenue Service (IRS) Independent Office of Appeals is launching two initiatives aimed at increasing transparency and fairness to taxpayers: (1) a Post Appeals Mediation pilot program, and (2) making Appeals Case Memos available to share with taxpayers.
Getting Help: It’s OK Federal Taxation, September 2025 Resources for lawyers who are struggling with substance abuse issues or mental health conditions.
Rural Practice Fellowship Program Federal Taxation, September 2025 Find out more about the 2026-2027 Rural Practice Fellowship Program. Applications will close on September 19, 2025. 
Spotlight on the 2025-26 Chair: Philip D. Speicher Federal Taxation, September 2025 Learn more about the 2025-26 Chair of the Federal Taxation Section Council, Philip D. Speicher! 
Tax Consequences of Settlement Agreements: Lessons From Mennemeyer v. Commissioner By Sandra D. Mertens Federal Taxation, September 2025 A case summary of the U.S. Tax Court matter, Adrienne Mennemeyer v. Commissioner of Internal Revenue, T.C. Memo 2025-80, and lessons learned on taxation of settlements. 
Changes to Estate Tax Planning May Be Needed for Closely-Held Businesses with Key Man Insurance Policies Securing Buy-Out Agreements By Sandra D. Mertens, Esq. Federal Taxation, December 2024 Recognizing that the business may not have the funds to redeem the deceased owner’s shares, the buy-out agreement may require the business to obtain “key person” insurance on the owners, which would be earmarked for the purchase price of the redemption.
Roundup of Recent IRS Penalty Abatement Caselaw By Sandra D. Mertens Federal Taxation, June 2024 Summaries of several recent court decisions with interesting penalty abatement results.
Tax Legislation Remains Stalled in Senate By Philip Speicher Federal Taxation, June 2024 The Tax Relief for American Families and Workers Act of 2024 is a $78 billion bipartisan tax bill that would extend or increase certain tax benefits for families and businesses, but its future appears uncertain after stalling in the Senate.
The Tax Code and Bankruptcy Code Collide: Navigating the Maze of IRS Income Tax Dischargeability in Chapter 7 Bankruptcy By Robert V. Schaller Federal Taxation, March 2024 In the ever-evolving landscape of bankruptcy law, the dischargeability of IRS back taxes via Chapter 7 bankruptcy remains a beacon of hope for many grappling with financial burdens.
U.S. Supreme Court to Decide Whether 2017 Mandatory Repatriation Tax Is Constitutional and Satisfies Due Process in Moore v. United States By Sandra D. Mertens Federal Taxation, March 2024 The Tax Cuts and Jobs Act of 2017 significantly changed portions of the U.S. tax code, including adding the Mandatory Repatriation Tax, which imposes tax on certain U.S. shareholders of foreign corporations.
The Corporate Transparency Act Will Be a Big Deal for Small Businesses By Sandra D. Mertens Federal Taxation, October 2023 On January 1, 2021, Congress enacted the Corporate Transparency Act, intended to prevent criminals from using companies for money laundering, corruption, tax evasion, drug trafficking, fraud, and other crimes.
Heads Up on CCA 202142010 By Patrick D. Owens Trusts and Estates, December 2022 The IRS caused some tax professions consternation when they issued Chief Counsel Advice 202142010.
2022 Takeaways From CPAR By Colin Walsh Federal Taxation, November 2022 The Centralized Partnership Audit Regime created a new system for the IRS to examine most Forms 1065.
A Guide to the Inflation Reduction Act’s Clean New Vehicle Credit By Philip D. Speicher Federal Taxation, November 2022 The Inflation Reduction Act, which adopts tax increases that are estimated to raise approximately $640 billion in additional tax revenue, was passed by Congress and signed by the president on August 16, 2022.
Heads Up on CCA 202142010 By Patrick D. Owens Federal Taxation, November 2022 The IRS caused some tax professions consternation when they issued Chief Counsel Advice 202142010.
Charitable Contributions: A Summary of the Deduction Rules By Kathy Garlow Trusts and Estates, May 2021 A look at the ways in which CARES Act and Consolidated Appropriations Act expanded the charitable contribution rules.
American Rescue Plan Act of 2021 - Nontaxable Unemployment Benefits State and Local Taxation, April 2021 The federally enacted American Rescue Plan Act of 2021 includes a retroactive provision making the first $10,200 per taxpayer of 2020 unemployment benefits nontaxable for individuals with modified federal adjusted gross income of less than $150,000. 
Charitable Contributions: A Summary of the Deduction Rules By Kathy Garlow Elder Law, April 2021 A look at the ways in which CARES Act and Consolidated Appropriations Act expanded the charitable contribution rules.
Charitable Contributions: A Summary of the Deduction Rules By Kathy Garlow Federal Taxation, March 2021 A look at the ways in which CARES Act and Consolidated Appropriations Act expanded the charitable contribution rules.
Impact Fund Considerations for Charitable Organizations By Colin J. Walsh Federal Taxation, March 2021 In recent years, impact funds have become a popular way for section 501(c)(3) charitable organizations to advance their tax exempt missions.
‘Financial Disability’ and the Suspension of the Statute of Limitation on Refund Claims By Nancy Franks-Straus Federal Taxation, December 2020 Although Congress intended to provide relief to taxpayers suffering from a significant mental or physical disability through the enactment of IRC § 6511(h), the strict interpretation given by the courts as to the authority of someone to act on taxpayer’s behalf has limited the application of the statute and thus limited the relief actually available to disabled taxpayers.
Illinois Attorney General Has Ramped Up Illinois Estate Tax Audits By Ryan A. Walsh Trusts and Estates, October 2020 Summaries of three cases from the last year in which Illinois estate tax returns were audited when no federal audit took place.
Illinois Attorney General Has Ramped Up Illinois Estate Tax Audits By Ryan A. Walsh Business Advice and Financial Planning, October 2020 Summaries of three cases from the last year in which Illinois estate tax returns were audited when no federal audit took place.
Illinois Attorney General Has Ramped Up Illinois Estate Tax Audits By Ryan A. Walsh Elder Law, October 2020 Summaries of three cases from the last year in which Illinois estate tax returns were audited when no federal audit took place.

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