Edward L. Froelich
Subscribe to Edward L. Froelich's PostsEdward L. Froelich represents domestic and foreign public corporations, privately held companies, partnerships, trusts and individuals across the spectrum of federal tax controversies, including audits, trials and appeals. Ed’s clients include businesses, business owners and investors with operations and interests in the financial services, technology, real estate, healthcare and other industries. Read Edward Froelich's full bio.
IRS roundup April 1 – April 9, 2026
By Kai M. Fenty and Edward L. Froelich on Apr 13, 2026
Posted In Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform, Trial Courts
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 1, 2026 – April 9, 2026. April 3, 2026: The White House proposed significant budget cuts to the Treasury Inspector General for Tax Administration (TIGTA), reducing its funding by nearly 17% for fiscal year 2027 to the lowest...
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The Employee Retention Credit: Ninth Circuit affirms denial of injunction, but leaves door open on merits
By Akiva B. Ungar and Edward L. Froelich on Mar 27, 2026
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, Significant Court Decision, Trial Courts
Case: ERC Today, LLC v. McInelly, Case No. 25-2642 (9th Cir. Mar. 17, 2026) We previously discussed the US District Court for the District of Arizona’s April 2025 order denying a motion for a preliminary injunction filed by two tax preparation firms challenging the Internal Revenue Services’ (IRS) automated “risking” model for processing Employee Retention...
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IRS roundup: March 9 – March 25, 2026
By Kai M. Fenty, Matthew J. Blaney and Edward L. Froelich on Mar 26, 2026
Posted In Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform, Trial Courts
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 9, 2026 – March 25, 2026. AI controversy developments March 20, 2026: The US Tax Court is considering developing a disciplinary framework for the misuse of artificial intelligence (AI) in litigation following concerns raised by Judge Mark V....
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Is your ERC claim protected? Keep an eye on litigation deadlines
By Akiva B. Ungar, Samuel F. Hamer and Edward L. Froelich on Mar 13, 2026
Posted In Court Procedure Matters, IRS Appeals, IRS Guidance, Tax Refunds, Trial Courts
In February 2026, the Internal Revenue Service (IRS) announced that, as of December 31, 2025, it had closed all non-examined Employee Retention Credit (ERC) claims. This development could compel businesses to pursue litigation to secure their ERC refunds. In its announcement, the IRS also noted that approximately 41,000 claims remain under IRS examination or appeal....
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IRS roundup: March 3 – March 10, 2026
By Kai M. Fenty, Matthew J. Blaney and Edward L. Froelich on Mar 10, 2026
Posted In Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform, Trial Courts
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 3, 2026 – March 10, 2026. IRS guidance March 3, 2026: The IRS released Revenue Procedure 2026-15, which provides the inflation-adjusted luxury automobile depreciation limits under Internal Revenue Code (Code) Section 280F for passenger vehicles, including trucks and...
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IRS roundup: February 9 – February 17, 2026
By Matthew J. Blaney, Suzanne Golshanara and Edward L. Froelich on Feb 24, 2026
Posted In IRS Guidance, Penalties, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for February 9, 2026 – February 17, 2026. IRS guidance February 9, 2026: The IRS issued Revenue Procedure 2026-13, providing discount factors for insurance companies to compute Section 846 discounted unpaid losses and recoverable Section 832 discounted estimated salvage for...
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New USPS postmark rules may impact tax filings
By Suzanne Golshanara, Edward L. Froelich and Matthew J. Blaney on Feb 13, 2026
Posted In IRS Procedure, Tax Refunds
Effective December 24, 2025, the United States Postal Service (USPS) adopted final rules that revise how postmarks are defined and treated. These changes have important implications for taxpayers who plan to mail their tax returns and rely on postmarks to establish timely filing. Under the new framework, the USPS has clarified and, in some cases,...
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IRS roundup: January 21 – February 9, 2026
By Suzanne Golshanara, Edward L. Froelich and Matthew J. Blaney on Feb 11, 2026
Posted In Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for January 21, 2026 – February 9, 2026. January 26, 2026: The IRS released Notice 2026-9, which provides a one-year extension to make certain amendments to individual retirement arrangements (IRAs), simplified employee pension arrangements, and savings incentive match plan for...
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IRS roundup: November 25 – December 10, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio, Matthew J. Blaney and Suzanne Golshanara on Dec 16, 2025
Posted In Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 25, 2025 – December 10, 2025. November 25, 2025: The IRS released Notice 2025-70, requesting comments on the implementation of a new individual tax credit under the newly enacted Section 25F under the One Big Beautiful Bill Act...
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Potential refund opportunity of buyback excise tax based on § 4501 final regulations
By Shawn O’Brien, Brian H. Jenn, Edward L. Froelich, Nick Ryan and Matthew J. Blaney on Dec 15, 2025
Posted In IRS Guidance, Tax Refunds
Taxpayers who paid the stock repurchase excise tax based on prior guidance provided in Notice 2023-2 and the proposed regulations under Internal Revenue Code (IRC) § 4501 may be entitled to a refund based on changes made in the recently issued IRC § 4501 final regulations. On November 21, 2025, the US Department of the...
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