A quarterly magazine from the National Association of Enrolled Agents
Fall 2026 vol.44 no.3
The Tax Risk Hiding in “Due From”
Feature Article

The Tax Risk Hiding in “Due From”

How informal owner advances and related-party transfers become tax problems. Most closely held business owners do not call their enrolled agent before moving money. They transfer funds... Alexander Jones, EA

Fall 2026, Feature Article, AFR, related-party, §7872, family-owned business, audit, closely held business, fair market value, §162, §482, §6001, applicable federal rate
When the Burden Shifts: Understanding Internal Revenue Code §7491(a)
Feature Article

When the Burden Shifts: Understanding Internal Revenue Code §7491(a)

The burden of proof in tax disputes generally is with the taxpayer, as established by Welch v. Helvering, 290 U.S. 111 (1933),i unless the taxpayer satisfies the conditions for burden shifting ... DeShawn King, EA

Fall 2025, Feature Article, Higbee v. Commissioner, Estate of Bongard, IRS Restructuring and Reform Act of 1998, §2036, Cohan rule, §274(d), IRC §7491(a), Welch v. Helvering, §6001, §7491(c), burden of proof