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New Authority, Borrowed Desks | JWellsTax Break 2026-08-03
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New Authority, Borrowed Desks | JWellsTax Break 2026-08-03

Senate Finance advances TAS Act, IRS runs on acting leadership, the Fifth Circuit rejects a deathbed family limited partnership, and the Second Circuit dismisses a premature dischargeability action

A Senate committee just advanced a bill that would put a background check and a continuing education requirement behind the PTIN — with a carve-out for EAs, CPAs, and attorneys. Meanwhile, the Fifth Circuit looked at a family limited partnership assembled during its owner’s final illness and said no. And the Second Circuit told a bankruptcy debtor she’d sued too early.


There was no episode last week, as I was at the NAEA Tax Summit. I taught a two-CE course on the § 199A qualified business income deduction and another two-CE course on reading and reviewing LLC operating agreements for non-attorney tax professionals. There won’t be an episode next week either, because I’ll be at the Pronto Tax School Knowledge Share Bootcamp, teaching two full-day workshops, one on S corporations and another on partnerships. If you’re in the Wilmington, North Carolina area, we’d love to see you in person, but if not, you can register to attend online!


Taxpayer Assistance and Service Act (S. 3931) full bill text

Senate Finance bill text: § 504 at pp. 99–117, § 903 at pp. 154–56

Senate Finance Committee announcement

Journal of Accountancy coverage

H.R. 1152, Electronic Filing and Payment Fairness Act

Loving v. IRS, 742 F.3d 1013 (D.C. Cir. 2014)

Treasury Office of Tax Policy

IRS Office of Chief Counsel at a Glance

Estate of Fields v. Comm., (5th Cir.)

In re Goebel (2d Cir.)

FinCEN BOI page (current rule)

Journal of Accountancy coverage

IR-2026–84, National Whistleblower Day

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