Skip to main content

S Corporation F Reorganizations Under Rev. Rul. 2008-18

John, a white man with dark brown hair, wears a pale blue shirt, lime green and blue tie, and black suit.
John G. Hodnette

An F reorganization, as discussed in The Basics of F Reorganizations, is a tax-free “mere change in identity, form, or place of organization of one…

Read More

Pandemic-Era Federal Tax Refunds: You May be Eligible, but the Deadline is Quickly Approaching

Brian, a white man with brown hair, wears a white shirt, navy suit and gold tie.
Brian C. Bernhardt

A recent case in the Court of Federal Claims confirmed taxpayers may be entitled to refunds of interest and penalties paid during the COVID-19 pandemic if…

Read More

Qualified Trade or Business Under Section 1202

John, a white man with dark brown hair, wears a pale blue shirt, lime green and blue tie, and black suit.
John G. Hodnette

and Savannah Rankich The general rules for qualified small business stock (“QSBS”) were discussed previously in “Gain Exclusion for Section 1202…

Read More

Section 453 Trap for S Corporation Asset Sales

John, a white man with dark brown hair, wears a pale blue shirt, lime green and blue tie, and black suit.
John G. Hodnette

In my prior post, Installment Sale Notes Owned by S Corporations, I discussed sales of S corporation assets in exchange for a promissory note, invoking the…

Read More

199A Deduction for Real Estate Rental Businesses

John, a white man with dark brown hair, wears a pale blue shirt, lime green and blue tie, and black suit.
John G. Hodnette

Section 199A, as discussed in my prior blog post Section 199A Pass-Through Deduction and the Magic Number, provides for a deduction generally equal to the…

Read More

Basics of 338(h)(10) Elections

John, a white man with dark brown hair, wears a pale blue shirt, lime green and blue tie, and black suit.
John G. Hodnette

Section 338(h)(10) allows a buyer and seller in a qualified stock purchase to elect jointly for the sale of target stock to be treated for tax purposes as a…

Read More

Bargain-Sale Pitfalls and the “Eerie Veneer” of NCMA’s “Madonna and Child in a Landscape”

Kim, a white woman with shoulder-length brown hair, wears a pin and orange dress and blue blazer with a small off-white flower pin. She is seated in her office.
Kimberly B. Tyson

On February 18th, the Center for Art Law is sponsoring a lecture by Deborah Gerhard, the Paul B. Eaton Distinguished Professor of Law at UNC School of Law.…

Read More

Substantiating Charitable Giving: Sibling Rivalry?

Kim, a white woman with shoulder-length brown hair, wears a pin and orange dress and blue blazer with a small off-white flower pin. She is seated in her office.
Kimberly B. Tyson

On January 6, 2026, in Gibson v. Commissioner, T.C. Sum. Op. 2026-1 (a nonappealable “S” case), the Tax Court sustained the IRS’s disallowance of a…

Read More

Exclusions to the Net Investment Income Tax

John, a white man with dark brown hair, wears a pale blue shirt, lime green and blue tie, and black suit.
John G. Hodnette

Since its enactment on March 30, 2010, in connection with the Affordable Care Act, Section 1411 has assessed an additional 3.8% income tax on individuals,…

Read More

Federal Income Tax Update

Keith, a white man with brown hair, wears wire-rimmed glasses, a white shirt and black jacket.
Keith A. Wood

1. Taxpayer Denied a Bad Debt Deduction even though the Borrower had Cancellation of Debt Income; Kelly v. Commissioner, 139 F.4th 854 (9th Cir. 2025).…

Read More