JWellsTax Break

Jeremy Wells, EA, CPA
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JWellsTax Break is a fast-paced weekly podcast for tax professionals who want to stay current without spending hours chasing headlines. Join Jeremy Wells, EA, CPA, each week for concise coverage of the latest IRS guidance, court decisions, legislation, and practice developments, with a focus on what they mean for real practitioners and real clients. Tax News. Practical Takeaways. Zero Fluff. www.jwells.tax

  1. 6d ago

    Refunds, audit AI, and ACA credit rules: The CP11 Tax Court Trap | JWellsTax Break 2026-10-19

    For the week of October 19, 2026, Jeremy explains which notices can support a Tax Court petition, a FOIA ruling about IRS audit-selection AI, and proposed premium tax credit regulations. Quick hits cover adoption-credit refunds, Hurricane Isaias deadline relief, a corrected refund-lookback rule, card payments, an ERC decision, and 2027 payroll planning. In this episode: * Tuohy v. Comm’r (3d Cir., Oct. 14, 2026): why a CP11 math-error notice and CP504 collection warning did not confer Tax Court jurisdiction. * Tax Analysts v. IRS (D.D.C., Oct. 14, 2026): the IRS must better explain why no portions of requested AI audit-selection data cards can be disclosed. * Premium tax credit proposed regulations, REG-101576-26 (Oct. 15, 2026): proposed eligibility, verification, computation, and reconciliation rules; comments due Nov. 30. * Blas v. Comm’r (9th Cir., Oct. 15, 2026): repayment of excess advance premium tax credits for 2014. * IRS adoption-credit announcement and carryforward FAQs (Oct. 16, 2026): automatic 2025 adjustments for certain 2020–2024 carryforwards; check the 2026 worksheet. * Hurricane Isaias relief—Alabama (Oct. 14, 2026): covered obligations postponed to Feb. 4, 2027. One sentence in the release gives a conflicting date. * Hurricane Isaias relief—Florida (Oct. 14, 2026): covered obligations postponed to Feb. 8, 2027. * Card-payment final regulations, T.D. 10060 (effective Oct. 19, 2026): permits IRS contracts for direct card payments with a reimbursement fee. * Tax Professional Awareness Week (announced Oct. 16, 2026): IRS webinar and practice resources. * November 2026 applicable federal rates, Rev. Rul. 2026-21 (posted Oct. 16, 2026). * 2027 Social Security wage base and COLA (announced Oct. 14, 2026): $192,300 taxable maximum; 3.6% benefit increase. * Southern Arizona Health Services Phoenix, LLC v. United States (Fed. Cl., Oct. 14, 2026): the staffing agency did not establish an ERC-qualifying suspension of its operations. * Disaster Related Extension of Deadlines Act, P.L. 119-64 (Dec. 26, 2025): changed the refund lookback treatment of disaster postponements for claims filed after enactment. * IRS casualty-loss update: the personal casualty-loss rule was made permanent and expanded to state-declared disasters beginning in 2026. Related Tax in Action: * Episode 6, “The Refund Statute of Limitations: When Time Runs Out” discusses refund claims. Its statement about disaster postponements and the refund lookback predates P.L. 119-64. * Episode 10, “When Disaster Strikes: Navigating Casualty Loss Deductions” covers casualty losses, insurance, and Form 4684; its description of the personal loss restriction predates the 2025 law. Get full access to JWellsTax at www.jwells.tax/subscribe

    Refunds, audit AI, and ACA credit rules: The CP11 Tax Court Trap | JWellsTax Break 2026-10-19

  2. Oct 13

    A personal note, zero basis, and $6.8M at stake: West’s partnership loss | JWellsTax Break 2026-10-12

    For the week of October 12, 2026, Jeremy covers the evidence needed to challenge an assessment and why a partner’s personal note did not create outside basis or satisfy the at-risk rules. There’s a reminder about the October 15 extended filing deadline. Quick hits cover military tax benefits, Form 56 filing addresses, the estate tax closing letter fee, and an enrolled taxpayer-advocate bill. In this episode: * October 15 extended filing deadline: most taxpayers with a valid extension for a 2025 individual return must file by Oct. 15, 2026; an extension of time to file did not extend the time to pay. * Ness v. Comm’r (10th Cir., Oct. 6, 2026): a missing return, Form 4340, and how to preserve a specific assessment challenge. * West v. Comm’r (T.C. Memo. 2026-105, Oct. 7, 2026): a claimed $6.8 million partnership loss, zero outside basis, an at-risk limit, and substantiation problems. * IRS military tax benefits update: possible benefits for qualifying service in Kenya, Mali, Burkina Faso, or Chad beginning Jan. 1, 2026. * IRS Form 56 filing-address clarification: Dallas Insolvency is reserved for specified fiduciaries. * Estate tax closing letter fee, T.D. 10055: $76 for requests received after Oct. 26; $56 through Oct. 26. * H.R. 997, enrolled bill (Oct. 9, 2026): would authorize the National Taxpayer Advocate to appoint counsel if enacted. Related Tax in Action: Episode 34, “Partnership Exits: Basis, Liabilities, and Hot Assets” explores outside basis, partnership liabilities, and suspended losses. Get full access to JWellsTax at www.jwells.tax/subscribe

    A personal note, zero basis, and $6.8M at stake: West’s partnership loss | JWellsTax Break 2026-10-12

  3. Oct 5

    An Audit Clock Keeps Running: Form 872-T and Assessment Extensions | JWellsTax Break 2026-10-05

    In this episode: Trump Accounts and the step to claim one; assessment consents and Fine & Dias; fraud and an expired assessment period in Mitchell; trust fund recovery penalties after a corporate compromise in Amodio; a purported joint return in Daidone; Israel-related deadline relief; scholarship and farmland regulations; the National Taxpayer Advocate bill. Primary sources * Treasury, October 1: Automatic enrollment for Trump Accounts. * Fine & Dias v. Comm’r, 167 T.C. No. 13 (Sept. 30, 2026). * Mitchell v. Comm’r, T.C. Memo. 2026-102 (Sept. 30, 2026). * Amodio v. Comm’r, T.C. Memo. 2026-96 (Sept. 28, 2026). * Daidone v. Comm’r, T.C. Memo. 2026-98 (Sept. 28, 2026). * IRS, September 30: Notice 2026-63, Israel-related deadline relief. * Treasury/IRS, October 2: T.D. 10057, temporary scholarship credit regulations and REG-117199-25, proposed regulations. * Treasury/IRS, September 29: REG-117095-25, proposed farmland installment election regulations. * U.S. Senate, September 28: H.R. 997 floor action and bill text; proposed amendment to IRC § 7803(c). Passed both chambers; enactment was not confirmed when these notes were prepared. Related JWellsTax and Tax in Action * JWellsTax Break, July 20, 2026: Trump Account gift-tax reporting safe harbor. * Tax in Action, Episode 6: The Refund Statute of Limitations: When Time Runs Out. This episode covers the separate deadline for refund claims. Get full access to JWellsTax at www.jwells.tax/subscribe

    An Audit Clock Keeps Running: Form 872-T and Assessment Extensions | JWellsTax Break 2026-10-05

  4. Sep 28

    A late partnership petition survives an IRS notice problem | JWellsTax Break 2026-09-28

    In this episode, the IRS rolls out a new mobile app, the Tax Court allows equitable tolling of a late centralized partnership audit petition, and we cover an Appeals dispute, updated travel per diem guidance, and an Opportunity Zone comment request. Sources and further reading IRS app announcement (Sept. 25, 2026) Kings Road Property, LLC v. Comm’r, 167 T.C. No. 11 (Sept. 21, 2026) Toscano Holdings, LLC v. Comm’r, T.C. Memo. 2026-90 (Sept. 22, 2026), opinion text Notice 2026-60, 2026–2027 special per diem rates Notice 2026-55, Opportunity Zone request for comments Get full access to JWellsTax at www.jwells.tax/subscribe

    A late partnership petition survives an IRS notice problem | JWellsTax Break 2026-09-28

  5. Sep 1

    The IRS Auditor Who Fabricated His Own Schedule C | JWellsTax Break 2026-08-31

    Janangelo — Civil fraud against an IRS revenue agent Janangelo, T.C. Summary Opinion 2026-8 (Aug. 27, 2026): CourtListener FIRE → IRIS transition IR-2026-99 (Aug. 24, 2026): IRS.gov Saver's Match Notice 2026-48, IRB 2026-35 (Aug. 24, 2026): IRS.gov Comments due October 5, 2026 Gutierrez-Chapin — Horse breeding and §183 Gutierrez-Chapin, T.C. Memo. 2026-76 (Aug. 27, 2026): CourtListener Trump Accounts correction Federal Register correction (Aug. 24, 2026): Federal Register TAS Act Taxpayer Assistance and Service Act — reported out of Senate Finance Committee 26-1 (July 30, 2026): Senate Finance Committee Get full access to JWellsTax at www.jwells.tax/subscribe

    The IRS Auditor Who Fabricated His Own Schedule C | JWellsTax Break 2026-08-31

  6. Aug 25

    Refundable Credits May Become a 'Federal Public Benefit' | JWellsTax Break 2026-08-24

    Refundable credits * Proposed regulations, REG-119882-25 (Aug. 20, 2026) * IR-2026-93 — Treasury and IRS news release * Comments due October 5, 2026; public hearing October 14, 2026. Requests to speak and outlines due October 5; requests to attend by 5 p.m. ET October 9. Submit at regulations.gov (reference REG-119882-25). Conservation Easements * IR-2026-95 — IRS establishes Office of Conservation Easements and transitions settlement process * Norcave Properties, L.L.C. v. Internal Revenue Service, No. 25-30542 (5th Cir. Aug. 21, 2026) Sec. 6213(a) Deadlines * Kyick Holdings, LLC, Transferee v. Commissioner, No. 25-1429 (1st Cir. Aug. 17, 2026) FBAR * United States v. Bowden, No. 25-cv-525 (AHA) (D.D.C. Aug. 17, 2026) Paid Family and Medical Leave Credit * Notice 2026-28, Internal Revenue Bulletin 2026-34 (Aug. 17, 2026) * Comments due October 16, 2026 — reference Notice 2026-28 at regulations.gov, docket IRS-2026-0496 Fourth Quarter Interest Rates * IR-2026-98 — rates unchanged for the quarter beginning October 1, 2026 * Rev. Rul. 2026-15 (PDF) — appearing in Internal Revenue Bulletin 2026-36, August 31, 2026 Defined Benefit Plan Funding * Proposed rule — Determination of Target Normal Cost and Funding Target for Single-Employer Defined Benefit Plans (Aug. 20, 2026) Practice Management Minute * IR-2026-92 — Security Summit reminder on Written Information Security Plans Get full access to JWellsTax at www.jwells.tax/subscribe

    Refundable Credits May Become a 'Federal Public Benefit' | JWellsTax Break 2026-08-24

  7. Aug 18

    The Fifth Circuit Reverses Itself, U.S. BOI Ends, Overtime Hits Box 12 | JWellsTax Break 2026-08-17

    Treasury press release on BOI Final rule on BOI (public inspection) FinCEN BOI FAQs K Alain LLLP v. Comm., No. 24-60240 (5th Cir. Aug. 12, 2026) Pending appeal, Denham Capital Mgmt. LP v. Bessent (1st Cir.) Pending appeal, Soroban Capital Partners LP v. Comm. (2d Cir.) Tax in Action Ep 32 — Limited Partner or Not? Why Courts Are Split on Your Tax Bill Earmark: "The Four Words Congress Never Defined" FS-2026-13 FS-2026-01 (prior version) IRS FAQ reliance policy Tax in Action Ep 37 — Qualified overtime deduction (publishing soon) Trump Accounts proposed regulations (IR-2026-90) Proposed rule, Trump Accounts + DCAP nondiscrimination Treasury release on Trump Accounts Maniktala v. Commissioner (8th Cir. Aug. 11, 2026) Boechler, P.C. v. Commissioner (8th Cir. Aug. 10, 2026) Rollover sample forms (IR-2026-91) FTC Safeguards Rule — what your business needs to know IRS: Tax preparers can follow these simple steps to protect client data Get full access to JWellsTax at www.jwells.tax/subscribe

    The Fifth Circuit Reverses Itself, U.S. BOI Ends, Overtime Hits Box 12 | JWellsTax Break 2026-08-17

  8. Aug 6

    New Authority, Borrowed Desks | JWellsTax Break 2026-08-03

    Taxpayer Assistance and Service Act (S. 3931) full bill text Senate Finance bill text: § 504 at pp. 99–117, § 903 at pp. 154–56 Senate Finance Committee announcement Journal of Accountancy coverage H.R. 1152, Electronic Filing and Payment Fairness Act Loving v. IRS, 742 F.3d 1013 (D.C. Cir. 2014) Treasury Office of Tax Policy IRS Office of Chief Counsel at a Glance Estate of Fields v. Comm., (5th Cir.) In re Goebel (2d Cir.) FinCEN BOI page (current rule) Journal of Accountancy coverage IR-2026–84, National Whistleblower Day Get full access to JWellsTax at www.jwells.tax/subscribe

    New Authority, Borrowed Desks | JWellsTax Break 2026-08-03
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About

JWellsTax Break is a fast-paced weekly podcast for tax professionals who want to stay current without spending hours chasing headlines. Join Jeremy Wells, EA, CPA, each week for concise coverage of the latest IRS guidance, court decisions, legislation, and practice developments, with a focus on what they mean for real practitioners and real clients. Tax News. Practical Takeaways. Zero Fluff. www.jwells.tax

Information

  • Creator
    Jeremy Wells, EA, CPA
  • Years Active
    2026
  • Episodes
    16
  • Rating
    Clean
  • Copyright
    © Jeremy Wells, EA, CPA
  • Show Website
    JWellsTax Break

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