The Tax Times: 2026

Thursday, March 5, 2026

What You Need to Know About 2026 Tax Filing Changes

With each new year comes a set of IRS and Treasury rule changes—some small, some significant—that can affect how and when you file your tax returns. While these updates may not have received much publicity, a few could materially impact both individual and business taxpayers.

Proof of Timely Filing: New Postal Rules

The Postal Service changed how it postmarks mail starting in December 2025. Mail is now postmarked based on when it’s processed at a regional sorting facility, not when it’s placed in a collection box. This means dropping your envelope at the post office near midnight on April 15 no longer guarantees a timely postmark.

To avoid late-filing penalties, taxpayers should:

· File electronically — the fastest method, providing immediate confirmation from the IRS.

· Request proof of mailing — options include a certificate of mailing, certified mail (with return receipt), or Priority Mail with tracking.

· Use an approved private delivery service — the IRS maintains a current list of approved carriers here.

Refunds Go Digital

Under a March 2025 Executive Order, Treasury is transitioning all payments—including tax refunds—away from paper checks to secure electronic transfers. Beginning with 2025 tax refunds, most individuals will receive funds by direct deposit or potentially via digital wallets. Paper checks are being phased out for individual taxpayers, though they continue for trusts, estates, and corporations.

If you haven’t done so already, provide your bank routing and account information when filing to avoid delays. And because Treasury’s implementation timeline continues to evolve, check with your tax preparer to ensure compliance.

Paying Taxes: Still Multiple Options

While Treasury is evaluating the possibility of phasing out paper checks for taxes due, individuals and trusts may still pay by mail or online. Accepted payment options include:

· Electronic Federal Tax Payment System (EFTPS) — required for large payments.

· IRS Direct Pay — a secure, no-fee online payment tool.

· Credit or debit card payments — available, though subject to processing fees.

Creating an IRS Online Account is also recommended. This provides access to payment history, prior returns, refund status, IP PIN applications, and installment agreement setup.

IRS Direct File: Program Ended

The IRS Direct File pilot, which allowed certain taxpayers to file simple returns directly with the IRS, ended in November 2025. However, several no-cost filing options remain:

· IRS Free File through partner software.

· Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE) programs.

· IRS Free Fillable Forms for those comfortable preparing returns manually.

Many of the 2026 filing season’s changes aim to modernize submission and payment systems, but they also narrow the margin for error. Plan ahead, confirm mailing and payment methods, and consult your tax professional to ensure a smooth and compliant filing experience.

Have an IRS Tax Problem?

Contact the Tax Lawyers at

Marini & Associates, P.A.

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Once Again The IRS Identifies Debt Resolution Companies as Scams on Its 2026 "Dirty Dozen List"

On July 16, 2020 we posted IRS Identifies Debt Resolution Companies as Scams on 2020 Dirty Dozen List!, where we discussed that the IRS 2020 "Dirty Dozen" list of tax scams for 2020 included Offer in Compromise Mills and advises Americans to be vigilant to these threats.

Now 6 years later in IR-2026-30, the IRS 2026 "Dirty Dozen" list of tax scams STILL includes Offer in Compromise Mills!

Offer in Compromise Mills: Taxpayers need to wary of misleading tax debt resolution companies that can exaggerate chances to settle tax debts for “pennies on the dollar” through an Offer in Compromise (OIC). These offers are available for taxpayers who meet very specific criteria under law to qualify for reducing their tax bill.

But Unscrupulous Companies Oversell The Program To Unqualified Candidates So They Can Collect A Hefty Fee From Taxpayers Already Struggling With Debt.

These scams are commonly called OIC “mills,” which cast a wide net for taxpayers, charge them pricey fees and churn out applications for a program they’re unlikely to qualify for.

"Offer Mills" can aggressively promote Offers in Compromise in misleading ways to people who clearly don't meet the qualifications, frequently costing taxpayers thousands of dollars.

Although the OIC program helps thousands of taxpayers each year reduce their tax debt, not everyone qualifies for an OIC.

The Agency's Rejection Rate is Roughly 67% .

Individual taxpayers can use the free online Offer in Compromise Pre-Qualifier tool to see if they qualify. The simple tool allows taxpayers to confirm eligibility and provides an estimated offer amount.

Taxpayers can apply for an OIC without third-party representation; but the IRS reminds taxpayers that if they need help, they should be cautious about whom they hire.

Have a Real Tax Problem?

Contact REAL Tax Attorneys!

Marini & Associates, P.A.

for a FREE Tax Consultation contact us at:
www.TaxAid.com or www.OVDPLaw.com or
Toll Free at 888-8TaxAid (888) 882-9243

Friday, February 27, 2026

CDP Is Not a Do‑Over: Diversified Group Learns That An Appeals Opportunity Can Be Fatal To a Tax Court Case If Ignored

In The Diversified Group Incorporated, 166 T.C. No. 2, 2/23/2026), the court held that an IRS post-assessment offer of an Appeals conference regarding assessable penalties is a prior “opportunity to dispute” the liability under section 6330(c)(2)(B), which bars later challenges to the underlying liability in CDP hearings and in Tax Court.

Core holding

· Diversified Group and its president James Haber were assessed section 6707 penalties (about 41.2 million dollars) for failing to register “Son-of-BOSS”–type tax shelters under section 6111 for 1999–2002.

· After assessment, the IRS sent letters (Dec. 2013 and Feb. 2014) expressly offering a conference with IRS Appeals and explaining how to protest the penalties.

· Petitioners declined to pursue Appeals and later tried to contest the penalties in CDP proceedings and then in Tax Court under section 6330(d).

· The Tax Court (Judge Toro) held that the offered Appeals conference was an “opportunity to dispute” the liability within the meaning of section 6330(c)(2)(B) and Treas. Reg. § 301.6330-1(e)(3) Q&A–E2.

· Because petitioners had that opportunity and chose not to use it, they were precluded from challenging the underlying section 6707 liabilities in their CDP hearings and thus in Tax Court, following Lewis v. Commissioner, 128 T.C. 48 (2007).

Key reasoning points

· An Appeals “opportunity” need not be a formal in‑person meeting; correspondence or calls with Appeals satisfy the regulation.

· Taxpayers cannot refuse to engage with the offered administrative remedy and then argue that the remedy was not “meaningful” or was “precooked.”

· A mere offer of Appeals review, when accompanied by clear instructions on how to obtain that review, is enough to trigger section 6330(c)(2)(B)’s bar, even for post‑assessment, non–deficiency penalties like section 6707.

Other issues

· The court granted the Commissioner partial summary judgment on the section 6330(c)(2)(B) issue and on the Appointments Clause argument; it held the Appeals settlement officer was properly appointed.

· The court did not reach the Eighth Amendment excessive fines argument because petitioners were entirely barred from disputing the underlying liability; that issue was therefore moot.

· A due process (Fifth Amendment) claim was not clearly raised and did not alter the result.

Practical takeaway for practice

For assessable penalties, if the IRS issues a post‑assessment letter offering Appeals review and explaining how to request it, that documented offer can permanently foreclose later liability challenges in CDP and Tax Court under section 6330(c)(2)(B) if the taxpayer does nothing. This makes it critical to calendar and respond to any Appeals‑offer letters in penalty cases, including section 6707 and similar promoter or information‑return penalty contexts.

Have an IRS Tax Problem?

Contact the Tax Lawyers at

Marini & Associates, P.A.

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Sources:

1. https://www.casemine.com/judgement/us/699d9ffc52d338fd3f6e77ee

2. https://www.currentfederaltaxdevelopments.com/blog/2026/2/24/tax-court-precludes-challenges-to-underlying-liabilities-in-cdp-proceedings-an-analysis-of-the-diversified-group-incorporated-v-commissioner

3. https://www.irs.gov/pub/irs-prior/p5286--122024.pdf

4. https://www.leagle.com/decision/intco20260223k63

5. https://www.currentfederaltaxdevelopments.com

6. https://www.smbiz.com/sbwday.html

7. https://kpmg.com/kpmg-us/content/dam/kpmg/taxnewsflash/pdf/2026/02/166-tc-no-1-jan28-2026.pdf

8. https://law.justia.com/cases/federal/appellate-courts/cafc/16-1014/16-1014-2016-11-10.html

9. https://www.law360.com/tax-authority/articles/2444947/tax-court-rejects-son-of-boss-promoter-s-penalty-dispute

10. https://www.vitallaw.com/news/promoters-barred-from-challenging-penalties-after-declining-appeals-review-the-diversified-group-incorporated-tc/ftd01e59aec15aba549658eadc683650a160a

11.

Thursday, February 26, 2026

IRS Launches New Web Page To Streamline Tax Fraud Reporting

In IR-2026-26 the Internal Revenue Service announced the launch of a new web page that allows taxpayers to confidentially report suspected tax fraud, scams, evasion, or other tax-related illegal activities, as well as internal-facing improvements that will enhance how referrals are used to stop illegal activity.

“Improvements to the IRS fraud reporting system make reporting suspected wrongdoing easier and simpler and will address historic challenges that had prevented the IRS from making maximum use of the referrals it receives,” said IRS Chief Executive Officer Frank J. Bisignano. “By reporting suspected tax fraud or scams, taxpayers play an important role in uncovering fraud and supporting the integrity of the nation’s tax system.”

The new web page consolidates multiple IRS fraud-reporting options into a single, centralized location, making it easier for taxpayers to report suspicious activity. The web page can be found by selecting the new ‘Report Fraud’ button on the IRS.gov homepage or at IRS.gov/SubmitATip. Taxpayers are encouraged to report suspected tax-related wrongdoing as soon as possible to help the IRS address fraud and noncompliance.

The new web page is only an initial improvement to the IRS’s fraud reporting process. Over the longer term, the IRS plans to streamline fraud reporting by reducing forms, automating processes, and using modern case management software.

These changes will address historic challenges the IRS has faced in using referrals. Creating fewer work streams, simplifying how taxpayers submit referrals, and making processing of claims more efficient will improve how IRS uses referrals in years to come.

Have an IRS Tax Problem?

Contact the Tax Lawyers at

Marini & Associates, P.A.

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Wednesday, February 25, 2026

White Collar Enforcement After Pullback Under President Trump

Recent data show that anti–money laundering (AML) fines in the U.S. fell from roughly $4.3 billion in 2024 to about $2.0 billion in 2025, a 54% decline that mirrors broader reports of a 58–61% drop in U.S. AML penalties as enforcement capacity shrank. At the same time, IRS Criminal Investigation cases targeting abusive tax schemes reportedly slid from 92 in 2024 to just 34 in 2025, a 63% fall and well below prior‑decade norms, even as IRS-CI continued to identify billions in tax fraud overall.

According to lawmakers, roughly 25,000 federal agents and career prosecutors who had previously focused on white collar matters were reassigned to immigration enforcement after January 2025, leaving many financial crime units “understaffed, under-resourced, and in some cases gutted.” This resource shift, paired with clemency that wiped out an estimated $1.3 billion in white collar restitution and fines, has been characterized by advocates as an extraordinary break from historic enforcement practice rather than a routine policy reprioritization.

Expert Warnings: Impunity Risk In A High‑Threat Era

Policy advocates and former enforcement officials warn that cutting back on complex financial investigations at this moment sends a dangerous signal of impunity in a global environment where financial crime risk is rising. Fenergo’s global data show total AML-related penalties fell 18% worldwide in 2025, but U.S. penalties dropped far more steeply than those in Europe and Asia, underscoring how much of the downturn is driven by U.S. resourcing and policy choices rather than a genuine fall in misconduct.

Experts highlight that technology is amplifying risk on multiple fronts: cryptocurrency has become mainstream and remains a powerful magnet for illicit finance, while rapid advances in artificial intelligence promise new tools for fraud, sanctions evasion and sophisticated laundering schemes. Against that backdrop, veteran regulators argue that pulling back experienced investigative staff and signaling leniency through pardons could embolden bad actors at home and abroad.

According to Law360 Money laundering-related fines and tax fraud investigations plummeted last year as President Donald Trump shifted federal agents away from combating financial crime to focus on the immigration crackdown, according to recent reports that have raised alarms among experts about the state of white collar enforcement in the U.S.:

FATF Scrutiny And The Risk Of A “Gray List”

This enforcement retreat coincides with the most significant review of U.S. AML defenses in a decade, as the Financial Action Task Force (FATF) conducts a full evaluation of U.S. compliance with global anti–money laundering and counter‑terrorist financing standards. FATF assessors are examining not just laws on the books but how effectively the U.S. uses those tools to detect, investigate and punish financial crime.

Advocates in the Financial Accountability and Corporate Transparency Coalition (FACT) warn that if the U.S. is viewed as failing to enforce its own rules, it could face a form of reputational downgrade similar to “gray‑listing,” in which jurisdictions are placed under enhanced monitoring for strategic deficiencies in their AML regimes. While gray‑listing is typically associated with smaller or emerging markets, being perceived as a weak link would make cross‑border banking and correspondent relationships more burdensome and could raise the cost and complexity of transacting through U.S. channels.

Congressional Pushback And DOJ’s Response

Alarmed by the trends, 27 Democratic lawmakers sent a January letter to federal inspectors general urging investigations into how the reallocation of roughly 25,000 agents away from white collar and corporate crime has affected fraud, tax evasion and money laundering enforcement. A separate letter from seven senators to Treasury Secretary and acting IRS Commissioner Scott Bessent and IRS-CI Chief Guy Ficco pressed for answers on the steep falloff in abusive tax scheme probes, which dropped 63% year‑over‑year and now sit about 40% below any other year in the last decade.

The U.S. Department of Justice has maintained publicly that assisting with immigration enforcement has not prevented it from successfully investigating and prosecuting white collar crime, pointing to ongoing work in areas such as healthcare fraud and False Claims Act litigation. DOJ’s Criminal Division also installed a new Assistant Attorney General in December and a new Fraud Section chief in January, changes some practitioners interpret as a sign of renewed stability and potential rebuilding of depleted white collar ranks.

How The Shift Is Reshaping White Collar Practice

On the ground, white collar defense lawyers report that active federal investigations have stalled or gone quiet, often after key agents left or teams were thinned out, leading some matters to “wither on the vine” rather than progress to charges. In response, many practitioners are pivoting from traditional criminal defense to a heavier mix of civil litigation, compliance counseling and internal investigations as demand shifts away from full‑scale criminal prosecutions.

Despite the downturn in AML penalties and tax scheme prosecutions, enforcement remains robust in pockets such as healthcare fraud, pandemic‑related benefit fraud and certain high‑profile bank and crypto cases, where penalties continue to reach into the hundreds of millions. Looking ahead, practitioners say the key questions are whether the administration will reallocate agents back to financial crime, how DOJ’s new leadership will prioritize corporate enforcement, and what signal FATF and global markets will send about the U.S.’s willingness to police money flows through its financial system.

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