This week we look at:

Informal claim and COVID-19 disaster relief save an untimely-looking IRA refund suit in Singh.
IRS recasts "Section 351 conversion" ETF transactions as taxable exchanges in Rev. Rul. 2026-20.
Proposed regs implement a four-year installment election for farmland sales to young farmers.
A corporate Offer-in-Compromise caps an officer's Trust Fund Recovery Penalty liability in Amodio.
Treasury completes automatic enrollment in Trump Accounts under new Section 530A regulations.
Sevillo Fine Foods: three independent grounds doom an ERC claim based on port congestion delays.
Tax Court holds Form 872-T cannot terminate a fixed-date Form 872 extension in Fine v. Commissioner.
New IRS notice extends tax deadlines to September 2027 for Israel conflict-affected taxpayers.
Congress sends the National Taxpayer Advocate independent legal counsel in H.R. 997.
New regulations build the infrastructure for the $1,700 Section 25F scholarship tax credit.

This week we look at:

• Tax Court Warns of AI Drafting Pitfalls in a CDP Lien Withdrawal Case -- Moore
• Altering the Perjury Jurat Dooms a Refund Suit -- Johnson v. IRS
• IRS Extends the Involuntary Conversion Period for Drought-Hit Livestock Sales
• H.R. 9500 Would Restore and Expand Personal Casualty and Theft Loss Relief
• Second Circuit Rejects Form Over Function for SECA Tax -- Soroban Capital Partners
• H.R. 5334 Expands the Educator Expense Deduction to Early Childhood Teachers

This week we look at:

• Tax Court Applies Equitable Tolling to BBA Partnership Petition Deadlines -- Kings Road Property
• District Court Voids VIBIR's Net Investment Income Tax Assessment -- Perkins
• IRS Notice 2026-55 Seeks Comments on Opportunity Zone Rules for Housing Developers
• Hurricane Michael Casualty and Charitable Deductions Fail for Lack of Substantiation -- Williams
• Treasury Raises the Estate Tax Closing Letter User Fee to $76 -- TD 10055
• Tax Court Finds Proper Mailing Despite a Defective Form 3877 -- Lindsey
• Unsubstantiated Insider Loan Triggers 225-Percent Excise Tax Exposure -- Jagannath