2025-04-19 Hobby Horse Problems
This week we look at:
- Navigating the 90-Day Deadline for Employment Tax Redeterminations: The Belagio Fine Jewelry, Inc. Case and Equitable Tolling
- GWA, LLC v. Commissioner: Substance Over Form and the Nuances of Tax Elections for Disregarded Entities
- Notice 2025-23: Treasury and IRS Signal Withdrawal of Basis Shifting TOI Regulations and Related Penalties
- Hobby Loss and Failure to File: A Deep Dive into Himmel v. Commissioner
