Feature Article 
Navigating the Contested Terrain of Surrogacy Expenses: A Case for Deductibility Under Internal Revenue Code §213
The landscape of family formation has undergone a profound transformation with the advent of assisted reproductive technologies (ARTs), including in vitro fertilization (IVF), egg donation, and gestational surrogacy. For many individuals and c... Zachary Hellman, EA, NTPI Fellow®
Fall 2025,
Feature Article,
adjusted gross income, AGI, private letter ruling, surrogacy expenses, §213, assisted reproductive technology, ART, in vitro fertilization, IVF, egg donation, gestational, §213(d)(1)(A), §1.213-1(e)(1)(ii), fertility, vasectomy, Publication 502, Magdalin v. Commissioner, Longino v. Commissioner, Morrissey v. United States, PLR 202114001, PLR 202505002, O’Donnabhain v. Commissioner, Osius v. Commissioner, Sedgwick v. Commissioner, Cassman v. United States, Kilpatrick v. Commissioner, H.R. 8190, §213(d)
Tax Court
Do Disproportionate Distributions Terminate an S Corporation Election?
S corporations cannot have more than one class of stock.i Based on this prohibition, many tax professionals believe that an S corporation that makes disproportionate distributions to shareholders terminates its S corporation e... Thomas A. Gorczynski, EA, USTCP