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2026-01-19 Fifth Circuit Reverses Tax Court on SE Income for State Law Limited Partners

Federal Tax Update Podcast

Release Date: 01/17/2026

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This week we look at: Supreme Court Invalidates Executive Tariffs Under IEEPA  Special Depreciation Allowance Under the OBBBA  CAMT Adjustments and Relief  Circuit Split on Third-Party Fraud  Valuation and Penalties in Syndicated Conservation Easements

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Federal Tax Update Podcast

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.

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This week we look at: The "Charitable LLC" Tax Shelter Section 280E Bars ERC for Cannabis Businesses TEFRA Intervention by Majority Partners R&D Credit Substantiation Supervisory Approval of Penalties ERISA Beneficiary Designations

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This week we look at: Challenging the Presumption of Delivery (CDP Cases) Bank Deposits & Conduit Theory Mandates Under Executive Order 14247 (Notice CP53E) IRS Implementation of Executive Order 14247 - (FS 2026-02) Federal Priority Statute Liability FASIT Structure & Substantial Compliance

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This week we look at: ERC Refund Suits and Challenges to IRS Notice 2021-20 Section 6015(f) Equitable Relief and Attribution of Income Financial Disability Tolling under § 6511(h) Distinguishing "Tax Loss" for Sentencing vs. Restitution Implementation of Qualified Overtime Deductions (OBBBA)

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2026-01-19 Fifth Circuit Reverses Tax Court on SE Income for State Law Limited Partners show art 2026-01-19 Fifth Circuit Reverses Tax Court on SE Income for State Law Limited Partners

Federal Tax Update Podcast

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

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Federal Tax Update Podcast

This week we look at: Standard Mileage Rates & Notice 2026-10 2026 Procedural Updates - Annual Revenue Procedures Qualified Passenger Vehicle Loan Interest (QPVLI) Proposed Regulations Estate of Spenlinhauer v. Commissioner Late Filing and More Bargain Sale of For-Profit colleges to a Non-Profit (501(c)(3))

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This week we look at: Executive Action on Marijuana Scheduling and IRC § 280E State Paid Family and Medical Leave (PFML) Programs Estimated Tax Relief for Qualified Farmland Sales IRC § 163(j) Interest Limitation Updates Premium Tax Credit (PTC) Revisions

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This week we look at: Section 25F Advance Elections Unreported Income & The "Missing Witness" Constitutionality of Penalties Post-Jarkesy Section 280E & Offers-in-Compromise Substantiating Bad Debt & NOLs

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Federal Tax Update Podcast

This week we look at USPS Changes to Postmark Date System H.R. 1491: Disaster Related Extension of Deadlines Act Capitalization Priorities: Temnorod v. Commissioner Notice 2026-5: HSA Expansion Under OBBBA Fulfillment by Amazon (FBA) and "Doing Business" Substantiation Failures: Mirch v. Commissioner

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More Episodes

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