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In this episode of the Tax Smart REI Podcast, Thomas Castelli and Nathan Sosa dive into a recent Tax Court case that's turning heads in the tax community. They break down how a taxpayer's DIY tax returns spiraled into a full-blown IRS audit, with the IRS reconstructing income through bank deposits, uncovering significant underreported receipts, and disallowing deductions when documentation couldn't be produced, including depreciation tied to rental properties. But the wildest part? The defense relied on AI-generated, hallucinated Tax Court case citations that didn't actually exist. It's an expensive lesson in why AI isn't ready to be your CPA and why “close enough” recordkeeping can get you crushed when the IRS starts asking questions. If you're investing in real estate, running a business, or leaning on AI for tax answers, this episode is a must-listen on why bookkeeping, documentation, and competent representation matter more than ever. To become a client, request a consultation from Hall CPA, PLLC at go.therealestatecpa.com/3KSEev6 Subscribe to REI Daily & Enter to Win a FREE Strategy Call: go.therealestatecpa.com/41JuQBX The Tax Smart Real Estate Investors podcast is for general information purposes only and is not intended to provide, and should not be relied on for, tax, legal, or accounting advice. Information on the podcast may not constitute the most up-to-date legal or other information. No reader, user, or listener of this podcast should act or refrain from acting on the basis of information on this podcast without first seeking legal and tax advice from counsel in the relevant jurisdiction. Only your individual attorney and tax advisor can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation. Use of, and access to, this podcast or any of the links or resources contained or mentioned within the podcast show and show notes do not create a relationship between the reader, user, or listener and podcast hosts, contributors, or guests. Any mention of third-party vendors, products, or services does not constitute an endorsement or recommendation. You should conduct your own due diligence before engaging with any vendor.
https://vimeo.com/1165157007?share=copy&fl=sv&fe=ci https://www.currentfederaltaxdevelopments.com/podcasts/2026/2/15/2026-02-16-hallucinations-enter-the-tax-court This week we look at: TEFRA Jurisdiction and the "Limited Partner" Exception Artificial Intelligence and Substantiation Section 183 Profit Motive Rebate vs. Nonrebate Refunds Substantiation and Civil Fraud Consolidated Return Jurisdiction
Attorney called out for suspected AI hallucinated cases by the Tax Court, First Circuit may be considering a method to avoid ruling on SE status or limited partners and more.
This week we look at: TEFRA Jurisdiction and the "Limited Partner" Exception Artificial Intelligence and Substantiation Section 183 Profit Motive Rebate vs. Nonrebate Refunds Substantiation and Civil Fraud Consolidated Return Jurisdiction Copyright 2026, Thomas, Zollars & Lynch Ltd.
The appellant, Bank of Nova Scotia (“taxpayer”), filed its return for the 2006 taxation year, reported taxable income, and paid such taxes as it calculated to be owing. The Minister of National Revenue (“Minister”) later audited the taxpayer's 2006 to 2010 taxation years. In March 2015, the taxpayer and the Minister entered into a settlement agreement which required additional amounts to be included in the taxpayer's 2006 income. The day before entering into the settlement agreement, the taxpayer wrote to the Minister to request to carryback a loss from its 2008 taxation year to apply it to offset the increase in its 2006 income. The Minister reassessed the taxpayer, implementing the audit adjustment and the requested loss carryback, and imposing interest resulting from the reassessment. The Minister applied a provision that requires that, for a specified period of time, interest is calculated by ignoring the loss carryback. The computing of interest that ignores the loss carryback ceases to apply 30 days after the latest of four end dates listed in s. 161(7)(b)(i)-(iv) of the Income Tax Act. The Minister computed interest by applying s. 161(7)(b)(iv) to ignore the loss carryback until the date the taxpayer requested it. The taxpayer appealed to the Tax Court of Canada, taking the position that s. 161(7)(b)(iv) did not apply because the Minister's reassessment of its tax for 2006 was not “as a consequence” of its request to carryback losses from 2008 to offset its 2006 tax liability. The Tax Court of Canada and the Federal Court of Appeal dismissed the taxpayer's appeal. Argued Date 2026-01-21 Keywords Taxation — Income tax — Computation of interest payable — Minister's reassessment taking into account audit adjustment and carryback requested by taxpayer to offset a loss — Minister applying s. 161(1)(b)(iv) of Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) to compute taxpayer interest up until day taxpayer requested loss carryback — Taxpayer appealing applicability of provision Minister relied on — Courts dismissing taxpayer's appeal — Whether the event set out in s. 161(7)(b)(iv) occurred when the Minister reassessed taxpayer's previous taxation year at a later date — What is the proper construction of s. 161(7)(b)(iv) and the words “where, as a consequence of a request in writing, the Minister reassessed the taxpayer's tax for [a previous year] to take into account the deduction” of a loss? — Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.), s. 161(7)(b)(iv). Notes (Federal) (Civil) (By Leave) Language English Audio Disclaimers This podcast is created as a public service to promote public access and awareness of the workings of Canada's highest court. It is not affiliated with or endorsed by the Court. The original version of this hearing may be found on the Supreme Court of Canada's website. The above case summary was prepared by the Office of the Registrar of the Supreme Court of Canada (Law Branch).
https://vimeo.com/1155580268?share=copy&fl=sv&fe=ci https://www.currentfederaltaxdevelopments.com/podcasts/2026/1/18/2026-01-19-fifth-circuit-reverses-tax-court-on-se-income-for-state-law-limited-partners This week we look at: SE Tax Liability for Limited Partners (Sirius Solutions) Whistleblower Awards and "Collected Proceeds" Statutory Construction of Section 168(k) Amendments Updated Safe Harbor Explanations for Section 402(f) Modernized Group Tax Exemption Framework Tax-Exempt Status of Supplemental Military Housing Allowances
Fifth Circuit throws out functional test on self-employment income for a limited partner, IRS restarts group tax exemption process and more.
This week we look at: SE Tax Liability for Limited Partners (Sirius Solutions) Whistleblower Awards and "Collected Proceeds" Statutory Construction of Section 168(k) Amendments Updated Safe Harbor Explanations for Section 402(f) Modernized Group Tax Exemption Framework Tax-Exempt Status of Supplemental Military Housing Allowances
In this episode of the Tax Smart REI Podcast, Thomas Castelli discusses the #1 tax strategy for 2026, plus a new tax court case involving the real estate professional status (REPS) and a short-term rental. If you're a high-income earner, this is for you. To become a client, request a consultation from Hall CPA, PLLC at go.therealestatecpa.com/3KSEev6 Subscribe to REI Daily & Enter to Win a FREE Strategy Call: go.therealestatecpa.com/41JuQBX The Tax Smart Real Estate Investors podcast is for general information purposes only and is not intended to provide, and should not be relied on for, tax, legal, or accounting advice. Information on the podcast may not constitute the most up-to-date legal or other information. No reader, user, or listener of this podcast should act or refrain from acting on the basis of information on this podcast without first seeking legal and tax advice from counsel in the relevant jurisdiction. Only your individual attorney and tax advisor can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation. Use of, and access to, this podcast or any of the links or resources contained or mentioned within the podcast show and show notes do not create a relationship between the reader, user, or listener and podcast hosts, contributors, or guests. Any mention of third-party vendors, products, or services does not constitute an endorsement or recommendation. You should conduct your own due diligence before engaging with any vendor.
Navigating the Federal Tax Controversy: From Audit to CourtThis conversation delves into the complexities of federal tax controversy, emphasizing the procedural landscape that taxpayers must navigate when facing IRS challenges. It covers misconceptions about tax filing, the distinction between tax avoidance and evasion, the importance of willfulness in tax defense, civil penalties, the audit process, document control, the assessment and collection phases, IRS enforcement tools, the appeals process, litigation paths, and the balance between tax collection and due process.In the complex world of federal tax controversy, understanding the procedural landscape is crucial. This isn't about tax rates or deductions; it's about the battlefield that emerges when the IRS challenges your return. From the initial audit to the high-stakes decision of where to litigate, the journey is fraught with procedural intricacies.The Misconception of Voluntary FilingA common misconception is that filing a federal tax return is voluntary. This misunderstanding stems from the phrase "voluntary assessment and payment," often misinterpreted by tax protesters. In reality, while the assessment is voluntary, the duty to disclose and pay is mandatory, as reinforced by the Internal Revenue Code.The Role of Penalties and CompliancePenalties play a significant role in ensuring compliance. The IRS imposes severe sanctions, including civil penalties and criminal prosecution, for those who attempt to subvert mandatory filing rules. Courts consistently reject arguments based on the voluntary premise, labeling them as legally meritless.Strategic Choices in LitigationChoosing the right judicial forum is a critical strategic decision. The U. S. Tax Court allows taxpayers to litigate without prepayment, offering a venue with judges who specialize in tax law. Alternatively, refund litigation in District Court or the Court of Federal Claims requires full payment upfront but offers the possibility of a jury trial.Mastery of procedural rules is as vital as understanding the substantive tax code. From the 90-day letter to the variance doctrine, procedural planning must precede substantive preparation. As you navigate this complex landscape, remember that the system is designed to ensure compliance through robust enforcement, not just civic goodwill.Subscribe now to stay informed on the latest in tax law and controversy.TakeawaysThe IRS challenges can be likened to a battlefield.Filing taxes is mandatory, not voluntary.Taxpayers must self-assess their tax liabilities.Tax avoidance is legal, while tax evasion is criminal.Willfulness is crucial in defending against tax charges.Civil penalties can be severe for non-compliance.The audit process begins with information requests.Document control is vital during IRS examinations.Tax assessments carry a presumption of correctness.Taxpayers have rights to challenge IRS actions.IRS, tax controversy, tax filing, tax evasion, tax avoidance, tax penalties, tax audit, tax litigation, tax compliance, tax law
When Jacob Dean looks back on his career, the through-line isn't a straight path — it's a steady climb built on curiosity, discipline, and the courage to rethink what success should look like. Raised in Northeast Ohio in a family of educators, Jacob grew up with a traditional definition of stability: find a good job, work hard, and build a dependable life. Entrepreneurship wasn't part of the conversation. Yet over time, Jacob discovered that he was drawn to something bigger — the intersection of law, business, and strategy.After majoring in finance, Jacob chose law school at a time when the economy was uncertain and job prospects were slim. But that step opened the door to a series of defining opportunities: working in the tax department at Procter & Gamble, clerking for the U.S. Tax Court, completing an LLM at Georgetown, and gaining meaningful experience in both law firm and in-house roles. Each chapter gave him new layers of expertise — tax structure, corporate operations, nonprofit compliance, and business management.Despite the steady progression, something deeper was brewing. Jacob realized that what energized him most wasn't just the practice of law — it was understanding how businesses run, how decisions get made, and how structure shapes success. He enjoyed the legal work, but he felt most at home thinking like an operator and strategist.Then came a turning point: turning 40. Instead of seeing it as a crisis, Jacob treated it as a moment of reflection — a chance to pause long enough to ask, What do I want the next decade to look like? The answer was clear: it was time to build something of his own.With support from family and colleagues, Jacob made the leap into entrepreneurship and launched his own firm. Unlike many attorneys who see the business side as a distraction, Jacob embraces it. He believes law firms should operate like true businesses — strategic, structured, and growth-minded — rather than relying on outdated norms or reactive hiring. His combined experience in tax and corporate law gives him a unique ability to help founders avoid pitfalls and build with intention.In this episode of The Inventive Journey, Jacob shares the decisions that shaped him, the pressure he once felt to take opportunities out of fear, and the mindset shift that now guides his career. He talks openly about learning to trust himself, redefining what a “successful” legal career looks like, and why entrepreneurship still excites him every day.His advice for new founders is refreshingly simple: get good help. Whether you're forming a company, raising capital, managing risk, or planning for growth, trying to do everything alone can cost far more than it saves. Good advisors, good structure, and good decision-making create the runway that businesses need to thrive.Jacob's story isn't just about leaving a job — it's about stepping into a role he was already preparing for through every chapter of his career. It's a reminder that experience compounds, reflection matters, and it's never too late to build a business on your own terms.
IRS discusses future guidance on federal scholarship tax credit, Tax Court deals a loss to another syndicated conservation easement and more.
In this ICYMI article-read, i+s Editor-in-Chief Carrie Meadows unpacks the renewed federal design directive from her article, “Architectural Community Responds to Trump's Executive Order on Federal Design,” originally published on Sept. 3, 2025, and why it's drawing pushback across the A&D community. You'll hear a concise overview of the order's call for classical styles, a quick history lesson on the 1962 “Guiding Principles for Federal Architecture,” and how groups like AIA, ASLA, the BSA, and the Society of Architectural Historians are responding. The episode explores what's at stake for community input, design innovation, and sustainability in federal projects—grounded with examples like the U.S. Tax Court and the rebuilt Alfred P. Murrah Federal Building—and closes with an editorial perspective on keeping civic architecture democratic, evidence-based, and future-forward.
More than 170 IRS attorneys have withdrawn from Tax Court cases since January, with dozens leaving the agency entirely. That's slowing litigation, prompting settlements, and weakening the government's ability to enforce tax laws. Here to explain what this exodus means for corporate accountability is Former Chief, DOJ Tax Division's appellate section, Gil Rothenberg.See Privacy Policy at https://art19.com/privacy and California Privacy Notice at https://art19.com/privacy#do-not-sell-my-info.
About the Guest(s):Paula M. Jones has been practicing law for almost 25 years. After a decade at large international law firms, she opened her own practice in 2016.LinkedIn - Paula M Jones, EsqHer domestic estate work includes wills, trusts, powers of attorney, living wills and beneficiary designations. She employs marital, residuary, disclaimer, dynasty, asset protection, grantor-retained annuity and intentionally defective grantor trusts, as well as family corporations to protect and preserve assets for many generations. She represents trustees and beneficiaries of trusts in trust-related matters. Her Orphans' Court practice includes trust reformations, trust mergers and divisions, terminations, accountings and audits. She represents parties in negotiations to avoid fiduciary litigation.Her work with international clients includes efficient planning in regard to U.S. estate and gift taxation, qualified domestic trusts, residency determinations, tax treaty applications, pre-immigration planning for non-resident aliens coming to the United States, expatriation tax planning for residents and citizens leaving the United States, administration of estates of foreign individuals with U.S. property and other related matters. She has represented many individuals in regard to foreign account and asset compliance issues.Paula is currently an adjunct professor at Western New England University School of Law where she teaches International Estate Planning. She has guest lectured at Columbia University, Temple University School of Law's Masters of Laws Program and Rutgers University School of Law. She lectures frequently for organizations such as the American Immigration Lawyers Association, Society for Human Resource Management and the American Bar Association, as well as local estate planning councils.Paula has authored several articles in respected industry journals such as Trusts and Estates, AICPA's Tax Advisor and the ABA's Practical Tax Lawyer. In addition, she developed a workshop on estate planning basics, titled “Will Power: Wealthy or Not, Your Estate Matters.” The companion book was published by The Graduate Group.Paula is admitted to practice in the State of New York, the Commonwealth of Pennsylvania, the State of New Jersey, the U.S. Tax Court and the U.S. District Court, Eastern District of Pennsylvania.Episode Summary:In this episode of the Money Roots podcast, host Amy Irvine engages in an enlightening discussion with Paula Jones, the esteemed owner of Jones Estate Group. With a robust background in international and domestic estate law, Paula delves into the intricacies of cross-border estate planning. She offers valuable insights into the roles her firm plays in estate planning, particularly emphasizing the importance of having a qualified team comprising estate attorneys, financial planners, and immigration lawyers when considering dual citizenship or cross-border living.Throughout the podcast, Paula addresses key issues associated with holding assets across different countries and the complex scenarios faced by individuals with multinational ties. Her discussion includes an exploration of residency determinations, tax treaty applications, and the vital significance of qualified domestic trusts in safeguarding assets. Paula's practical advice caters to a growing audience interested in international living, offering concrete steps to ensure seamless estate planning while navigating diverse legal systems.Key Takeaways:Having a qualified team of advisors, including an estate attorney, financial planner, and immigration lawyer, is crucial for...
Tax Court issues decision on handling W-2 wages for QBI purposes for cannabis business, "placed in service" definition clarified for pre-IRA electric vehicle credits, and more developments.
IRS releases guidance on changes in research and experimental expenditures, Sixth Circuit agrees with Second and Third Circuits on equitable relief for late Tax Court petitions in deficiency cases and more.
Kashi Way '99, a judge for the U.S. Tax Court, welcomes new UVA Law students at orientation. Dean Leslie Kendrick '06 introduced Way. (University of Virginia School of Law, Aug. 15, 2025)
https://vimeo.com/1110565833?share=copy#t=0 https://www.currentfederaltaxdevelopments.com/podcasts/2025/8/17/2025-08-18-state-tax-credit-salt-workaround-regulation-challenge-fails This week we look at: Denham Outlines Its Criticisms of the Tax Court's Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners Understanding New Clean Electricity Credit Termination Rules Impact of IRS Notice 2025-42 on Wind and Solar Facilities
This week we look at: Denham Outlines Its Criticisms of the Tax Court's Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners Understanding New Clean Electricity Credit Termination Rules Impact of IRS Notice 2025-42 on Wind and Solar Facilities
The Tax Court determines amounts paid were not a loan but rather equity and denied a claimed bad debt deduction, two cases on statutes of limitations and more.
A new study published by the Centre for Ecology and Hydrology shows that nature-friendly farming is not currently as profitable as intensive food production. Its authors say the report is the first of its kind and shows that agroecology improves biodiversity and can boost crop yields. However, the cost of creating habitats and the loss of some productive land, they say, means lower profits. Dr Ben Woodcock led the four year study which studied 17 farms.More big food companies are paying producers who farm regeneratively a premium, encouraging them to improve soil health, increase on-farm biodiversity and reduce their carbon footprint. Nestle is working with the farmers' cooperative First Milk to collect data from 80 UK farmers who supply them with milk and are being paid a premium to farm regeneratively. We visit one of their dairy farmers in Cumbria.One of the farmers seeking a judicial review of the treasury's decision to impose inheritance tax on farm businesses says the government failed to consult properly on changes to the tax. Tom Martin from Cambridgeshire tells us why he's taking part in the legal action.Presenter = Anna Hill Producer = Rebecca Rooney
In this case, the court considered this issue: Does a proceeding under 26 U-S-C § 6330 for a pre-deprivation determination about a levy proposed by the Internal Revenue Service to collect unpaid taxes become moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding?The case was decided on June 12, 2025.The Supreme Court held that the Tax Court lacks jurisdiction under 26 U-S-C §6330 to adjudicate disputes between a taxpayer and the IRS once the IRS is no longer pursuing a levy. Justice Amy Coney Barrett authored the 8-1 majority opinion of the Court.Section 6330 of the Internal Revenue Code grants taxpayers the right to a hearing before the IRS can levy (seize and sell) a taxpayer's property to collect unpaid taxes. At this hearing, a taxpayer can raise issues about the levy, including the existence or amount of the underlying tax liability, and the appeals officer makes a “determination” about whether the levy may proceed. The law then permits review of this “determination” by the Tax Court. The Tax Court's jurisdiction is strictly limited to reviewing the determination whether a levy may go forward, not every dispute considered at the hearing. If there is no longer a proposed or ongoing levy—for example, because the taxpayer's liability has been zeroed out during the pendency of the appeal—there is no determination left to review, and thus, no case or controversy for the Tax Court to resolve under §6330.The reasoning rests on several points: (1) The statutory text and structure focus the collection due process hearing and subsequent Tax Court review on the levy alone; (2) The default rule in tax litigation is that challenges to tax liability must proceed as refund suits after payment, except where specifically authorized exceptions, like the collection due process review, apply; and (3) The statute does not authorize the Tax Court to issue refunds or declaratory judgments unrelated to stopping a levy. Therefore, after the IRS drops the levy because the tax debt has been satisfied, any continuing disputes about liability or overpayment must proceed through a refund suit in district court, not in the Tax Court under §6330.Justice Neil Gorsuch authored a dissenting opinion, arguing that the Tax Court retains jurisdiction over all issues addressed in the IRS's determination—including disputes about underlying tax liability—even after a levy is abandoned, and that stripping jurisdiction in these circumstances creates opportunities for the IRS to evade judicial review and leaves taxpayers without meaningful remedies for erroneous IRS actions.The opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.
Join Newton One Advisors (Mark Singer and Stephen Target) and Marty Babitz, Family Wealth Strategist for BNY Mellon Wealth Management, as they delve into the U.S. Tax Court Ruling on the Hoensheid v. Commissioner case. The discussion focuses on the tax implications of donating appreciated stock in a closely held corporation to charity just before the company's sale.
Another Circuit looks into the equitable tolling issue for Tax Court deficiency petitions, an US Air Force civilian contractor issued orders to move cannot claim moving expenses and more.
Taxpayer fails to justify equitable relief for late filing of employment tax related Tax Court petition, Tax Court found horse operation was subject to the hobby loss rules and more.
https://vimeo.com/1070813367?share=copy#t=0 https://www.currentfederaltaxdevelopments.com/podcasts/2025/3/30/2025-03-31-end-of-paper-tax-payments-and-refund-checks-coming This week we look at: Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021 Interim Final Rule Limiting BOI Filing Requirements Released by Treasury Department Substantiating Depreciation for Converted Property: A Look at Smith v. Commissioner Executive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related Ones Jones et al. v. Commissioner: A Deep Dive into the Tax Court's Scrutiny of a Microcaptive Insurance Arrangement Navigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United States Ninth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAs
This week we look at:Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021Interim Final Rule Limiting BOI Filing Requirements Released by Treasury DepartmentSubstantiating Depreciation for Converted Property: A Look at Smith v. CommissionerExecutive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related OnesJones et al. v. Commissioner: A Deep Dive into the Tax Court's Scrutiny of a Microcaptive Insurance ArrangementNavigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United StatesNinth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAsAn audio only version of this week's broadcast can be streamed or downloaded below: Articles on this week's update can be downloaded below:2025-03-31 Current Federal Tax Developments
Chris's Summary:This week's EDU show is a throwback to an old favorite—things that make you go “hmm.” Jim brought back a list of oddities from the latest Ed Slott training, covering everything from RMD rules the IRS only recently addressed to real-world court cases involving bankruptcy, lottery tickets, and IRA self-dealing gone wrong. Turns out, […] The post Things That Make You Go Hmm – RMD Rules, IRA Mistakes, and Tax Court Surprises: EDU #2512 appeared first on The Retirement and IRA Show.
This Day in Legal History: Nuclear Non-Proliferation TreatyOn March 5, 1970, the Nuclear Non-Proliferation Treaty (NPT) officially took effect, marking a major milestone in global efforts to prevent the spread of nuclear weapons. The treaty, first opened for signatures in 1968, was ratified by 43 nations and established a framework based on three core principles: non-proliferation, disarmament, and the peaceful use of nuclear energy. Under its terms, nuclear-armed states agreed not to transfer nuclear weapons or technology to non-nuclear states, while non-nuclear countries pledged not to pursue nuclear weapons. In return, signatories were guaranteed access to nuclear energy for peaceful purposes, such as power generation and medical research. The treaty also called for eventual nuclear disarmament, though progress on this front has been slow and uneven. The NPT has since become one of the most widely adhered-to arms control agreements, with 191 countries now party to it. However, key states like India, Pakistan, and Israel never joined, while North Korea withdrew in 2003. The treaty's effectiveness has been challenged by nuclear programs in states like Iran and North Korea, as well as concerns over compliance by nuclear-armed signatories. Despite these challenges, the NPT is reviewed every five years at Review Conferences, where nations assess progress and negotiate future commitments. The treaty remains central to international non-proliferation efforts, balancing national security interests with the goal of reducing nuclear threats worldwide.In his primetime address to Congress, President Donald Trump defended his aggressive tariff policies, claiming they would generate significant revenue and restore economic balance. He downplayed concerns over rising consumer prices, characterizing them as a temporary inconvenience. While Trump briefly addressed inflation, blaming high costs on his predecessor, he provided few concrete solutions. Instead, he focused on politically charged topics like immigration and cultural issues, declaring an end to "wokeness." His speech coincided with growing economic concerns, including stagnating factory activity and declining consumer confidence, while markets reacted negatively to escalating trade tensions. New tariffs on Canada, Mexico, and China sparked fears of inflation and economic slowdown, though his administration suggested potential relief for North American allies. Trump also called for the repeal of the Chips Act, arguing tariffs were more effective in boosting domestic industry. He promoted energy independence but proposed long-term projects unlikely to have an immediate impact. Meanwhile, his executive actions have rapidly reshaped government policies, sparking bipartisan concerns. The speech underscored Trump's efforts to push his economic agenda while navigating political and economic challenges.Trump Hails Tariffs as US Economy Barrels Into Trade WarsThe U.S. Tax Court ruled that a $3.1 million grant given to a Cantor Fitzgerald subsidiary after the Sept. 11 attacks is taxable income. The grant, provided in 2007 through New York City's World Trade Center Job Creation and Retention Program, was meant to help businesses recover, but the court determined it did not qualify as a tax-exempt gift or disaster aid. Despite this, the court waived $211,000 in penalties, acknowledging the complexity of tax laws at the time. Cantor Fitzgerald, which lost 658 employees in the World Trade Center attacks, had argued the funds should not be considered taxable, citing past Supreme Court rulings. However, Judge Kathleen M. Kerrigan found that the payments were not an act of disinterested generosity but an effort to stimulate economic recovery. The IRS had initially determined in 2007 that the company owed about $1.1 million in taxes for not reporting the grant on its tax returns. While Cantor Fitzgerald contested the classification, the court upheld the IRS's position, reinforcing that government aid programs do not automatically qualify for tax exemption.Cantor Fitzgerald's Sept. 11 Relief Grant Deemed Taxable IncomeFederal judges are facing an increase in threats as Elon Musk and Trump allies intensify their attacks on the judiciary over rulings that hinder White House policies. The U.S. Marshals Service has warned judges about heightened security risks, especially as Musk has repeatedly criticized judges on his social media platform, calling them “corrupt” and “evil.” Some judges have received anonymous deliveries, like pizzas, in what authorities see as intimidation tactics. Musk's posts, along with calls from Republican lawmakers to impeach certain judges, have coincided with a rise in violent threats, particularly against judges who have blocked parts of the administration's plans to cut government jobs and aid programs. One judge, Amir Ali, received death threats after ruling against a Trump executive order, with online users calling for his execution. The American Bar Association and the Federal Judges Association have condemned these attacks, warning that continued intimidation could undermine judicial independence. Since 2020, threats against federal judges have more than doubled, and legal experts caution that targeting judges for their rulings could destabilize the rule of law.Exclusive: Judges face rise in threats as Musk blasts them over rulings | ReutersTwo Trump EPA nominees are facing Senate scrutiny over the agency's possible plan to roll back the 2009 “endangerment finding,” which forms the legal basis for regulating greenhouse gas emissions under the Clean Air Act. The nominees, Aaron Szabo and David Fotouhi, would oversee efforts to reverse this finding, which has supported climate regulations on power plants and vehicle emissions. EPA Administrator Lee Zeldin has recommended reconsidering the finding to the White House, though details remain undisclosed. While the Supreme Court's 2007 ruling in Massachusetts v. EPA confirmed greenhouse gases as air pollutants, the 2022 Inflation Reduction Act further solidified the EPA's authority. However, the EPA under Trump previously avoided overturning the rule due to industry resistance. Some industry groups, like the Edison Electric Institute, have expressed reliance on EPA authority for emissions regulation, while automakers have yet to take a position. Zeldin acknowledged the EPA's authority to regulate greenhouse gases but suggested it is not obligated to do so, fueling debate over the agency's future climate policies.Top EPA nominees face Senate scrutiny over plan to undo key climate finding | Reuters This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit www.minimumcomp.com/subscribe
Intro Summary] In this follow-up episode of Absolute Trust Talk, host Kirsten Howe welcomes back tax law expert Tony Kim to continue their deep dive into IRS audits and appeals. With 26 years of experience working for the IRS, Tony provides invaluable insights into what happens after an audit determination is made. He explains the role of a protest letter, how appeals officers function as mediators, and why IRS litigation can be risky for taxpayers. Throughout the episode, Tony emphasizes the importance of organization, professionalism, and strategic decision-making when dealing with the IRS. He also shares real-world examples of how cases are resolved at different stages of the appeals process. If you're facing an IRS audit or just want to understand your rights, this episode is packed with essential knowledge. Time-stamped Show Notes: 0:00 Introduction 1:33 The protest letter: Here's what you need to know about how it challenges IRS decisions. 4:20 Appeals officers vs. revenue agents—who decides your case? 6:16 The power of appeals—why 90% of cases never reach court. Here's why. 8:50 Tax Court vs. District Court: Listen in as Kirsten and Tony discuss the key differences and taxpayer options. 10:44 The IRS attorney's role—can they make things better or worse? 14:31 Next, Tony is sharing important strategies for working effectively with the IRS—what really works? 19:38 How do you determine what to look for when selecting the right tax attorney? Tune in for key considerations. 23:37 Final advice—why staying engaged in your case is crucial!
Attorney George Smith is a highly respected and well-known attorney throughout the State of Alabama. As most attorneys in the state know George, I have known him by reputation, and this is really the first time for me to speak in depth with him. George is a graduate of the University of Alabama School of Law and he also received an LLM in tax law from the New York University School of Law. Following that, he clerked in Washington DC for a judge on the U.S. Tax Court for two years before returning back to Huntsville to start his law practice. George has practiced with large Alabama law firms throughout his career. He has been at Bradley since 2012. As you'll hear, even with his impressive background, George is easy to talk to and I can well imagine that his clients appreciate the skill and practicality he brings as he represents them. Since George has practiced in “big law” for his entire legal career, we also discussed a number of his friends and colleagues that are also very prominent lawyers in Alabama to include Pat Graves, Frank Caprio, Bartley Loftin, David Holt, Kevin Gray, Chris Hinson and Joe Ritch. I enjoyed getting to know George on this episode of the podcast and I think you will like his humble and up-tempo spirit!
This lecture begins by outlining the historical and constitutional roots of the federal income tax. Early in American history, the federal government used excise taxes and tariffs to raise revenue, and only in special circumstances, such as the Civil War, did it introduce temporary income taxes. The Sixteenth Amendment in 1913 dramatically shifted the legal landscape, giving Congress the authority to impose an income tax without the need for apportionment among the states. This development paved the way for modern federal income taxation, removing most constitutional barriers that had previously hindered direct taxation of individual incomes.Next, the lecture covers how the federal tax system is organized. The Internal Revenue Service (IRS) enforces tax laws and issues guidance, while the Treasury Department oversees both the IRS and broader financial policies. Various authorities define tax law: the Internal Revenue Code (IRC) enacted by Congress; Treasury Regulations that interpret and clarify the Code; official Revenue Rulings and procedures from the IRS; and judicial decisions at multiple levels, including the U.S. Tax Court, district courts, courts of appeal, and potentially the Supreme Court. Together, these sources form a complex legal framework that practitioners must navigate.Tax policy goals also factor into the system's structure. While the primary purpose of taxation is to fund government operations, Congress uses the tax code to shape economic and social behavior, encouraging homeownership via mortgage interest deductions or fostering charitable giving through donation write-offs. This means that the Code is more than just a revenue-raising tool; it's also a mechanism for incentivizing and discouraging certain activities.A significant portion of the lecture is devoted to gross income, a concept anchored by IRC Section 61. This broad definition—“all income from whatever source derived”—captures wages, business profits, interest, dividends, rents, and many other forms of economic gain. Even illegal proceeds and certain prizes count as gross income, reflecting the principle that if a taxpayer obtains a clear economic benefit, it is presumed taxable. Nevertheless, there are notable exclusions: gifts, inheritances, certain fringe benefits, and life insurance proceeds are among the items that Congress or the courts have decided should not be included in gross income. Sometimes, these exclusions further a policy objective, such as not penalizing individuals receiving gifts or not taxing life insurance benefits that mitigate financial burdens upon death.The lecture then introduces the importance of filing status: single, married filing jointly, married filing separately, head of household, and qualifying widow(er). Each status affects how taxpayers fall into brackets in the progressive tax system, where higher marginal rates apply to additional increments of income. The system aims to tax those with greater resources more heavily, though fairness and efficiency debates remain. Thus, individuals with the same gross income may pay different effective tax rates, influenced by both filing status and the presence of deductions or credits.Finally, the lecture underscores the policy rationales embedded in the tax code. Deductions for retirement contributions or energy-efficient home improvements reveal the government's intent to channel societal behaviors. Because these incentives directly affect how people earn, save, and invest, attorneys and other professionals must understand both the letter of the law and the broader purpose it serves.Overall, Lecture 1 underscores that modern federal income taxation rests on a constitutional foundation, shaped by the Sixteenth Amendment, enforced by a multi-tier system of statutes, regulations, and court rulings, and guided by deliberate policy goals. The core concept of “gross income”—and the many exceptions that reduce it—forms the building block for tax liability calculation
This week we look at: IRS issues letter ruling on IRA left to trust A taxpayer mistakenly believes the IRS had conceded that his income was not subject to self-employment tax, but it hadn't The Tax Court denies a taxpayer's deductions and claimed partnership losses due to incredibly disorganized and inadequate records Taxpayer runs afoul of the “pay first, litigate later” rule when attempting to sue the IRS for a refund in US District Court in response to an assessment A taxpayer's unprocessed claim for an ERTC refund doesn't justify CDP relief The BOI - new Administration continues litigation and proposes a new due date, potential filing relief
https://vimeo.com/1052761467?share=copy#t=0 https://www.currentfederaltaxdevelopments.com/podcasts/2025/2/2/2025-02-03-a-week-of-tax-court-rulings This week we look at: Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on Return IRS Finds Most Expenses Related to Taxpayers' In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213 Taxpayer Denied Innocent Spouse Relief in Tax Court Bench Opinion Tax Court Finds No Issue With the Appeals Office Structure and Staffing Failure to Provide Proof of Filing of Returns Fatal to Taxpayer's Attempt at Obtaining Relief in CDP Hearing Despite IRS Procedural Errors
Tax Court reduces donation amount to less than 1/3 of original amount claimed, taxpayer's decision to play hardball in a collection issue backfires. and more.
This week we look at: Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on Return IRS Finds Most Expenses Related to Taxpayers' In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213 Taxpayer Denied Innocent Spouse Relief in Tax Court Bench Opinion Tax Court Finds No Issue With the Appeals Office Structure and Staffing Failure to Provide Proof of Filing of Returns Fatal to Taxpayer's Attempt at Obtaining Relief in CDP Hearing Despite IRS Procedural Errors
https://vimeo.com/1048354337?share=copy#t=0 https://www.currentfederaltaxdevelopments.com/podcasts/2025/1/19/2025-01-20-secure-20-act-proposed-guidance This week we look at: IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 property Proposed regulations on catch-up contributions added by the SECURE 2.0 Act Proposed regulations on the automatic enrollment provisions of IRC §414A US Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process case IRS issues final regulations on resolution of tax controversies by the IRS Independent Office of Appeals Under TFA of 2019
IRS releases two sets of proposed regulations under the SECURE 2.0 Act, IRS agrees to hear case on Tax Court jurisdiction in CDP cases and more.
This week we look at: IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 property Proposed regulations on catch-up contributions added by the SECURE 2.0 Act Proposed regulations on the automatic enrollment provisions of IRC §414A US Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process case IRS issues final regulations on resolution of tax controversies by the IRS Independent Office of Appeals Under TFA of 2019
This week we look at: IRS gives relief for specific identification of digital asset basis for certain taxpayers for 2025 only Department of Justice asks the U.S. Supreme Court to Stay the Latest Corporate Transparency Act Injunction IRS no longer to dispute requirement to comply with APA to add listed transactions after the enactment AJCA in 2024 Tax Court rules that merely being in a registered historic area does not make a building a certified historic structure Tax Court finds taxpayer owes tax on over $5.3 million diverted from two retirement plans
BOI updates continue throughout the week, Ninth Circuit rules on all events test issue and Tax Court again imposes functional test on state law limited partners
Jeannette is joined by Dr Kameel Khan,a lawyer, judge, and founder of Project Remake, about his inspiring journey from Trinidad to the UK and his commitment to social justice. Kameel shares his early influences, including the civil unrest in Trinidad and the impact of his parents' belief in education. He also discusses his experiences defending death row inmates and the complexities of the justice system, highlighting the importance of understanding the human stories behind offenders. KEY TAKEAWAYS The journey into law and social justice was significantly influenced by early education and the support of family, highlighting the role of encouragement and vision in shaping one's future. Understanding the personal stories and backgrounds of offenders is crucial. They are not just statistics; they are individuals with families and potential who deserve a second chance. Project Remake, which started at Stanford University, focuses on entrepreneurship training for formerly incarcerated individuals, achieving a remarkable 6% reoffending rate compared to the national average of 54%. The financial burden of incarceration is significant, with costs reaching £50,000 per year per inmate. Investing in rehabilitation and employment opportunities for ex-offenders can lead to better societal outcomes and reduced costs. BEST MOMENTS "We have had 120 graduates, and we have had a 6% reoffending rate... The national average is near 54% in the first year and 70% in the second year." "We want to live in a society that doesn't write people off, that gives people a second chance." "How do we break that sort of aspect of judgment around this whole topic? Because I think that's a really big blocker as well, the perception." "It's very interesting... finding your voice is a huge thing... realising you could only be you, everyone else is taken." This is the perfect time to get focused on what YOU want to really achieve in your business, career, and life. It’s never too late to be BRAVE and BOLD and unlock your inner BRILLIANT. Visit our new website https://brave-bold-brilliant.com/ - there you'll find a library of FREE resources and downloadable guides and e-books to help you along your journey. If you’d like to jump on a free mentoring session just DM Jeannette at info@brave-bold-brilliant.com. VALUABLE RESOURCES Brave Bold Brilliant - https://brave-bold-brilliant.com/ Brave, Bold, Brilliant podcast series - https://podcasts.apple.com/gb/podcast/brave-bold-brilliant-podcast/id1524278970 ABOUT THE GUEST Kameel Khan is a lawyer, judge and former law professor. Before practicing he taught law at University College, University of London, Reading University and the University of the West Indies. He was a Visiting Scholar at Harvard Law School. Recently he was DCI Fellow at Stanford University. While teaching law he defended people on death row from the Caribbean before the Privy Council (UK), the highest court of Appeal for that region. He later became a tax partner at a global law firm and then a judge in the Tax Court in the UK. Kameel headed the Ex-Offenders Programme at The King's Trust Mosaic, which was created by HRH King Charles to provide mentoring and training to young offenders . He sat on the board of The King's Trust Mosaic. Kameel was born in Trinidad & Tobago. He studied at the London School of Economics and received a doctorate in law from McGill University, Montreal, Canada. When not lawyering he plays club cricket and listens to jazz. He likes to cook and spends the summer at his house in Italy on the Tuscan/Umbrian border. He is married and has two daughters; one a lawyer and the other a surveyor/urban planner. His interest lies in the rehabilitation of ex-offenders and in working together with similar minded people. He founded Project Remake a charity which provides jobs and entrepreneurial training to Prison leavers. ABOUT THE HOST Jeannette Linfoot is a highly regarded senior executive, property investor, board advisor, and business mentor with over 30 years of global professional business experience across the travel, leisure, hospitality, and property sectors. Having bought, ran, and sold businesses all over the world, Jeannette now has a portfolio of her own businesses and also advises and mentors other business leaders to drive forward their strategies as well as their own personal development. Jeannette is a down-to-earth leader, a passionate champion for diversity & inclusion, and a huge advocate of nurturing talent so every person can unleash their full potential and live their dreams. CONTACT THE HOST Jeannette’s linktree - https://linktr.ee/JLinfoot https://www.jeannettelinfootassociates.com/ YOUTUBE - https://www.youtube.com/@braveboldbrilliant LinkedIn - https://uk.linkedin.com/in/jeannettelinfoot Facebook - https://www.facebook.com/jeannette.linfoot/ Instagram - https://www.instagram.com/jeannette.linfoot/ Tiktok - https://www.tiktok.com/@brave.bold.brilliant Podcast Description Jeannette Linfoot talks to incredible people about their experiences of being Brave, Bold & Brilliant, which have allowed them to unleash their full potential in business, their careers, and life in general. From the boardroom tables of ‘big’ international businesses to the dining room tables of entrepreneurial start-ups, how to overcome challenges, embrace opportunities and take risks, whilst staying ‘true’ to yourself is the order of the day.Travel, Bold, Brilliant, business, growth, scale, marketing, investment, investing, entrepreneurship, coach, consultant, mindset, six figures, seven figures, travel, industry, ROI, B2B, inspirational: https://linktr.ee/JLinfoot
Tax Court looks at how to handle a situation where a partner deducted losses in excess of basis in a year no longer open to assessment and more.
This week we look at: IRS may stop putting “taxpayer may rely” statements on proposed regulations Tax Court rules partnership basis calculations are cumulative in nature and not stand-alone annual calculations under IRC §705 Latest speculations on what will get through Congress in 2025 - if anything
The IRS is winning more cases in the US Tax Court over companies' valuation of intangible assets, such as patents and trademarks, through transfer pricing. The wins have caught the attention of companies and practitioners as they mull the growing risks of transfer pricing, which governs transactions between related companies that are part of the same multinational group. Disputes between the IRS and companies such as Coca-Cola and 3M have showcased the agency's newfound ability to audit their positions and win in Tax Court when challenged. Both cases are being appealed. In addition, a new IRS policy to assess more penalties when documentation is lacking could make companies' transfer pricing positions much riskier than in the past, practitioners say, and taxpayers may have to start factoring that in. In this week's Talking Tax podcast, Bloomberg Tax reporter Caleb Harshberger spoke with Grant Thornton LLP Transfer Pricing Technical Leader Steve Wrappe and Greenberg Traurig LLP shareholder Sharon Katz-Pearlman about how the IRS has changed its approach and what additional funding from the 2022 Inflation Reduction Act means for taxpayers moving forward. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
Taxpayers who engage in tax fraud face serious consequences, including steep penalties, endless assessment-periods, prolonged trials, reputational damage, and more. Mere allegations of fraud by the IRS can trigger these types of damaging outcomes. Cynics often argue that this is precisely the reason the IRS sometimes claims that fraud occurred in the first place. Fortunately for taxpayers, while alleging fraud is relatively easy, proving it can be hard for the IRS. Two recent Tax Court cases, analyzed in this article, demonstrate this reality.
In this episode of The Million Dollar Flip Flops Podcast, Rodric Lenhart sits down with Charles Read, President and CEO of Get Payroll. Charles, a seasoned CPA and U.S. Tax Court practitioner, talks about the common pitfalls around payroll and compliance, revealing how businesses can navigate a changing landscape.Charles discusses the recent rule changes affecting independent contractors, the political influences on these regulations, and the potential impact on businesses. He also highlights the common mistakes in payroll processing - such as misclassification - that can lead to costly penalties.What You'll Hear in This Episode:The potential impact of regulatory changes on the gig economy Key payroll pitfalls and how to avoid themWhy accurate payroll processing is crucial to avoid penaltiesThe importance of professional payroll services for business ownersSome of the common hiring mistakes that can land you in hot waterQuote: "You're a successful businessman... but when the IRS comes calling, you're Beckham at second base. You're out of your league."– Charles ReadGuest Links:Get Payroll WebsiteCharles Read on LinkedInResources:Million Dollar Flip FlopsFollow Us on InstaIf you aren't 100% confident what your ‘next right move' is in your business…I may have a tool that can help. Take the Entrepreneurial Journey Quiz and find out which stage you are in and which areas to focus on.Take the quiz now: https://milliondollarflipflops.com/quiz/
In this episode of Breaking Battlegrounds, we kick it off with Congressman Juan Ciscomani of Arizona's 6th Congressional District, who gives us the latest developments regarding the Trump assassination task force, the most recent job reports released, and his bipartisan affordable housing bill in Congress. Following this, Joe Bishop-Henchman from the National Taxpayers Union Foundation will discuss the impact of tariffs on the economy, the recent Chevron decision on businesses, and Biden's outrageous White House payroll. Finally, Alexander Raiken from the Ethics and Public Policy Center presents his analysis on how Donald Trump does not pose a threat to democracy. Tune in for an in-depth exploration of these pivotal issues shaping the political landscape.-www.breakingbattlegrounds.voteTwitter: www.twitter.com/Breaking_BattleFacebook: www.facebook.com/breakingbattlegroundsInstagram: www.instagram.com/breakingbattlegroundsLinkedIn: www.linkedin.com/company/breakingbattlegrounds-Show sponsors:Invest YrefyYrefy offers a secure, collateralized portfolio with a strong, fixed rate of return - up to a 10.25%. There is no attack on your principal if you ever need your money back. You can let your investment compound daily, or take your income whenever you choose. Make sure you tell them Sam and Chuck sent you!Learn more at investyrefy.com4Freedom MobileExperience true freedom with 4Freedom Mobile, the exclusive provider offering nationwide coverage on all three major US networks (Verizon, AT&T, and T-Mobile) with just one SIM card. Our service not only connects you but also shields you from data collection by network operators, social media platforms, government agencies, and more.Use code ‘Battleground' to get your first month for $9 and save $10 a month every month after.Learn more at: 4FreedomMobile.comDot VoteWith a .VOTE website, you ensure your political campaign stands out among the competition while simplifying how you reach voters.Learn more at: dotvote.vote-About our guests:Congressman Juan Ciscomani represents Arizona's 6th Congressional District in the United States House of Representatives. Juan and his family immigrated to the United States when he was a young boy. They established roots in Tucson, Arizona, where his father worked as a bus driver to give his children a shot at the American Dream. Growing up in a working class family taught Juan the value of hard work and the importance of a can-do attitude.Juan attended public schools in Tucson, Pima Community College and the University of Arizona. He worked his way through school with maintenance and service jobs until becoming the first in his family to graduate from college. After college, Juan worked for the University of Arizona and the Tucson Hispanic Chamber of Commerce before joining Arizona Governor Doug Ducey's administration as Senior Advisor and Vice-Chair of the Arizona-Mexico Commission. Juan focused on the issues of international trade and diplomacy, border security, and economic development.In 2022, Juan was elected to represent Arizona's new 6th congressional district, becoming the first naturalized American citizen from Mexico elected to the U.S. House of Representatives in Arizona history.In 2024, Juan was named the most bipartisan member from Arizona in the U.S. House of Representatives by the Lugar Center and McCourt School of Public Policy at Georgetown University Bipartisan Index.Juan often shares a conversation with his dad where his dad asked him:“Where else could we have our story? We come to the US, learn English, immerse in the culture, become US citizens, I drive a bus most of my life, and now my son is a United States Congressman. Where else in the world? Nowhere else, that's the American Dream.”Juan is determined to fight to keep that dream alive for others. Juan resides in Tucson with his wife, Laura, and their 6 kids — Zoe, Juan David, Kenny, Lily, Lucas, and Gloria.-Joe Bishop‐Henchman is Executive Vice President at the National Taxpayers Union Foundation, leading our work to protect taxpayer rights through research, litigation, and outreach. He has worked with elected officials and stakeholders to achieve major state‐level tax changes, advised on the interplay between federal and state policy changes, and authored over 100 studies on tax policy and tax law. Bishop‐Henchman is a class plaintiff in a major lawsuit against the Internal Revenue Service seeking refund of $300 million of illegally collected fees, was lead counsel in NTUF's Halstead Bead litigation that successfully prompted reform of Louisiana's complex local sales tax practices, and his brief in South Dakota v. Wayfair was cited twice by the U.S. Supreme Court majority opinion.Bishop-Henchman joined NTUF from the McDermott Will & Emery law firm, where he counseled clients on tax policy and compliance, and prior to that, 14 years at the Tax Foundation, where he co-authored 8 books on tax policy. He has testified to Congress seven times, in 36 state houses around the country, and on anti-corruption tax reform efforts in-person in Kyiv, Ukraine in 2023. He was educated at the University of California, Berkeley and received his J.D. from the George Washington University Law School and a certificate in International Legal Studies from the University of the Pacific, McGeorge and the University of Salzburg. He is admitted to practice law in New York, Maryland, the District of Columbia, and before the U.S. Supreme Court, the U.S. Tax Court, and the 4th, 5th, 6th, 9th, and D.C. Circuits.-Alexander Raikin is a friend on the show. He is a Visiting Fellow in Bioethics and American Democracy Program at the Ethics and Public Policy Center. His research focuses on the dignity of human life and end-of-life issues, especially on its impact on the field of medicine and broader ethical questions of social belonging. His writing has been widely cited in major publications such as The Atlantic and the New York Times and in academic journals in the United States, Canada, UK, and France. He wrote cover stories for National Review and The New Atlantis, while his other bylines include City Journal, Plough, and the Washington Free Beacon. Raikin frequently speaks on national radio and on major podcasts.Last year, Raikin was an inaugural Richard John Neuhaus Fellow at the Public Interest Fellowship and EPPC. He was a Tikvah Summer Fellow and a Killam scholar with Fulbright at American University. He graduated from Carleton University with a bachelor's degree in public policy. Raikin is a proud member of Kesher Israel synagogue and lives with his wife in Washington, D.C. Get full access to Breaking Battlegrounds at breakingbattlegrounds.substack.com/subscribe
My guest in this episode is John Hyre. John Hyre is an attorney, accountant, and investor. For the first seven years of his career, he worked at two large accounting firms and served as Tax Counsel for a Fortune 500 Company, gaining extensive experience in corporate taxes. For the past 18 years, he has run both an accounting practice and a tax law practice, working with small businesses, real estate investors, note investors, and self-directed retirement accounts. He has prepared thousands of tax returns, provided tax planning and reduction strategies, and successfully represented clients in IRS audits and Tax Court. Additionally, he has invested in mobile home parks, low-income rentals, and property flips. John is also a frequent speaker and author on the taxation of real estate and IRAs, and he has written three home study courses and numerous articles. Interview Links: John Hyre website; https://www.taxreductionlawyer.com/. Subscribe To Our Weekly Newsletter: The Wealth Dojo: https://subscribe.wealthdojo.ai/ Download all the Niches Trilogy Books: The 21 Best Cashflow Niches Digital: https://www.cashflowninjaprograms.com/the-21-best-cashflow-niches-book Audio: https://podcasters.spotify.com/pod/show/21-best-cashflow-niches The 21 Most Unique Cashflow Niches Digital: https://www.cashflowninjaprograms.com/the-21-most-unique-cashflow-niches Audio: https://podcasters.spotify.com/pod/show/21-most-unique-niches The 21 Best Cash Growth Niches Digital: https://www.cashflowninjaprograms.com/the-21-best-cash-growth-niches Audio: https://podcasters.spotify.com/pod/show/21-cash-growth-niches Listen To Cashflow Ninja Podcasts: Cashflow Ninja https://podcasters.spotify.com/pod/show/cashflowninja Cashflow Investing Secrets https://podcasters.spotify.com/pod/show/cashflowinvestingsecrets Cashflow Ninja Banking https://podcasters.spotify.com/pod/show/cashflow-ninja-banking Connect With Us: Website: http://cashflowninja.com Podcast: http://resetinvestingsecrets.com Podcast: http://cashflowinvestingsecrets.com Podcast: http://cashflowninjabanking.com Substack: https://mclaubscher.substack.com/ Amazon Audible: https://a.co/d/1xfM1Vx Amazon Audible: https://a.co/d/aGzudX0 Facebook: https://www.facebook.com/cashflowninja/ Twitter: https://twitter.com/mclaubscher Instagram: https://www.instagram.com/thecashflowninja/ TikTok: https://www.tiktok.com/@cashflowninja Linkedin: https://www.linkedin.com/in/mclaubscher/ Gab: https://gab.com/cashflowninja Youtube: http://www.youtube.com/c/Cashflowninja Rumble: https://rumble.com/c/c-329875 --- Send in a voice message: https://podcasters.spotify.com/pod/show/cashflowninja/message