I don’t report IRS bulletins or, as a rule, decisions of courts other than Tax Court. The trade press and blogosphere get there first, with resources I don’t have.

But the latest IRS E-news for Tax Professionals has two (count ’em, two) items that foretell whence two sources of blogfodder might spring.

First, IRS announced that anyone filing an amended return to claim a refund for taxes paid under Section 280E (the potters’ field), because certain herbal medicaments are State-legal, will get a swift right-about-face from IRS. More refund cases in Tax Court?

Second, IRS is sending settlement proposals to some of those enmeshed in syndicated conservation easement deals and like dodges. Except those with filed petitions, and those not selected by IRS to come and join the dance, cannot participate. I don’t know if the letters go only to TMPs or representatives (who presumably can bring the rest of their crew with them or not), or whether individual partner-levels can settle out. But the IRS Notice IR-2024-174, June 26, 2024, does the Acts 9:1 number on the non-settlers.

Warms my jagged old heart…more blogposts to come.