Keith A. Wood
Federal Income Tax Update
I. Conservation Easement Deed did not Constitute a CWA because it did not Contain a Merger Clause; Martin vs. Commissioner, TC Memo 2026-39. A.…
Federal Income Tax Update
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).…
Federal Income Tax Update
I. Wife Not Entitled to Any of Foreclosure Sales Proceeds of Husband’s Marital Home to Pay Husband’s Taxes Since Title was Solely in the Husband’s Name;…
Federal Income Tax Update
I. 2024 IRS Audit Statistics. The 2024 IRS Data Book released in April 2025 contains audit statistics for years 2014 through 2022, as of the fiscal year ended…
Federal Income Tax Update
I. Real Property Distributed from Testamentary Trust Meets the Section 1031 “Held for Investment” Requirement; PLR 202449007. A testamentary trust…
Federal Income Tax Update
I. IRS Cannot Impose Tax on Withdrawals from an IRA It Seized; Hubbard v. Commissioner, 135 AFTR 2d 2025-484 (6th Cir). Mr. Hubbard was a Kentucky pharmacist.…
Federal Income Tax Update
I. Sections 453 and 1042 Deferral Provisions Can Apply in the Same ESOP Transaction; Berman vs. Commissioner, 163 TC No. 1 (2024). In 2002, Mr. and Mrs.…
Federal Income Tax Update
I. Conservation Easement Charitable Deduction Limited to Taxpayer’s Basis in Ordinary Income Property; Oconee Landing Property vs. Commissioner, TC Memo…
Federal Income Tax Update
I. Thanksgiving Holiday Extends the Due Date for Filing Tax Court Petition; Sall vs. Commissioner, 161 T.C. No. 13 (2023). Mr. Sall received a notice of…
Federal Income Tax Update
I. 2023 Audit Statistics; Chances of Being Audited. The 2023 Internal Revenue Service Data Book released in April 2024 contains audit statistics for years…