On September 4, 2026, the IRS and Treasury Department published proposed regulations (REG-119986-25) that would redefine the nondiscrimination standards every tax-exempt private school must meet under section 501(c)(3). If finalized, these rules could require meaningful changes to admissions policies, scholarship
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July 2019
Latest from Tax Controversy Report
IRS Revenue Officers Will Be Knocking on Doors in Lancaster County This August – Here’s What You Need to Know
If you own a business or reside in Lancaster County, pay close attention: the IRS confirmed in a July 21, 2026 letter that 20 revenue officers will be conducting face-to-face visits with taxpayers in the community during the weeks of
Tax Court Holds BBA Partnership Petition Filing Deadline Is Not Jurisdictional
In Big Apple Tompkins Realty LLC v. Commissioner, the Tax Court addressed a question of first impression: whether I.R.C. § 6234(a)’s 90-day petition filing deadline for partnerships subject to the Bipartisan Budget Act of 2015 (BBA) audit rules is
The Growing Business of Sports: A Tax Playbook Review
Get your popcorn ready because there is nothing more exciting than the intersection of sports and tax! As a former Division II athlete, the current state of college sports and Name, Image, and Likeness (NIL) deals is fascinating. Student-athletes typically
No Points for Participation: Passive Activity Rules and Loss Limitations
Classroom participation points may boost a child’s grade in history class, but merely raising your hand won’t get you far with the IRS. The passive activity loss rules under I.R.C. § 469 can make a real economic loss feel like
IRS Launches Online Portal for Kwong Refund Claims
On July 1, 2026 the IRS unveiled a new portal for Kwong related refund claims. Taxpayers who want file Forms 843 claiming a refund for interest or penalties that accrued between January 20, 2020 and July 10, 2023 can file
IRS Targeting Charitable Deductions: Old Dog, Old Tricks
At the NYU Tax Controversy Forum last week, (former?) Acting IRS Chief Counsel Ken Kies commented on the IRS conservation easement settlement initiative and noted that the IRS is looking into what he calls “easement-like” charitable donations of
Rhetoric Aside, Audits of Tax-Exempt Organizations Skyrocketed in FY25
The current administration’s focus on tax-exempt organizations is no secret. But the recent release of the IRS Databook for FY25 shows that the IRS is following through on the administration’s publicly announced objectives. Based on information from IRS Databooks
Horse Breeding and Training Expense Deductions? Tax Court Says Neigh
In a June 9 opinion, the Tax Court held that a married couple were not engaged in horse breeding and training activities for profit and sustained the IRS’s disallowance of the taxpayers claimed loss deductions for three tax years.
Taxpayer Assistance and Service Act Title X: Miscellaneous Provisions
This is the final post in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act, a bipartisan legislative package introduced on February 26, 2026, by Senate Finance Committee Chairman Mike Crapo (R-Idaho)