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Weekly IRS Roundup September 2 – September 6, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Sep 13, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 2, 2024 – September 6, 2024.

September 2, 2024: The IRS released Internal Revenue Bulletin 2024-36, which includes Notice 2024-63. The notice provides guidance on matching contributions for qualified student loan payments under § 401(k) of the Internal Revenue Code (Code) and other similar retirement plans. This guidance aims to help plan sponsors with setting up these programs for plan years beginning after December 31, 2024, until proposed regulations are issued.

September 3, 2024: The IRS reminded taxpayers to develop or update their emergency preparedness plans as part of National Preparedness Month, especially with the peak of hurricane season imminent and elevated wildfire risks. Key steps include protecting and duplicating essential documents, creating property inventories, and knowing how to reconstruct records if needed.

September 4, 2024: The IRS announced it is using funding from the Inflation Reduction Act of 2022 (IRA) to modernize taxpayer services with new online tools, including the IRS Energy Credits Online platform, which simplifies the process for claiming clean energy credits. These improvements aim to save taxpayers time and money while enhancing compliance and fraud mitigation.

September 4, 2024: The IRS released Revenue Procedure 2024-34, which modifies Revenue Procedure 2024-23 to provide procedures under Code § 446 for obtaining automatic consent to change accounting methods for Code § 174 research or experimental expenditures paid or incurred after December 31, 2021. The new revenue procedure also limits audit protection for these expenditures if changes are not made in the applicable tax year.

September 4, 2024: The IRS reminded tax professionals to be vigilant for signs of data breaches, such as slow computer performance, unexpected cursor movements, and clients receiving IRS authentication letters for returns they did not file. Immediate reporting to the IRS and proactive measures, such as obtaining an Identity Protection PIN, are crucial to mitigate the impact of data theft.

September 5, 2024: The IRS encouraged taxpayers to use Identity Protection PINs and establish an IRS online account to safeguard against identity theft and fraud. These tools help protect personal and financial information from being stolen by scammers.

September 5, 2024: The IRS reminded taxpayers that the deadline for the third quarter estimated tax payment is September 16, 2024. Taxpayers in disaster-affected areas in 17 US states, Puerto Rico, and the Virgin Islands may qualify for an extended deadline.

September 5, 2024: The IRS released Notice 2024-65, requesting public comments on the implementation of Saver’s Match contributions, a new initiative under Code § 6433 aimed at boosting retirement savings for low-to-moderate-income individuals. Public comments are sought on various aspects, including eligibility, claiming processes, and outreach to traditionally marginalized communities, with a deadline of November 4, 2024.

September 6, 2024: The IRS announced [...]

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Weekly IRS Roundup August 26 – August 30, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Sep 6, 2024 | IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26, 2024 – August 30, 2024.

August 26, 2024: The IRS released Internal Revenue Bulletin 2024-35, which includes the following:

Revenue Ruling 2024-16, which provides the average annual effective interest rates for new loans under the Farm Credit System and lists the states within each Farm Credit System Bank Territory. These rates are used to compute the special use value of farmland for estate tax purposes under § 2032A of the Internal Revenue Code (Code).
Announcement 2024-32, which revokes the Code § 501(c)(3) determination for specified organizations and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).
Proposed regulations that address issues under the dual consolidated loss rules, including the treatment of certain disregarded payments that result in losses for foreign tax purposes. These regulations clarify the interaction of dual consolidated loss rules with intercompany transactions under Code § 1503(d) and introduce rules for foreign hybrid entities.

August 26, 2024: The IRS identified new warning signs of incorrect Employee Retention Credit claims and urged businesses to review their filings to ensure eligibility and avoid mistakes. Common issues include unsupported claims of business suspension, wages paid to family members, and wages reported as payroll costs to qualify for the loan forgiveness.

August 27, 2024: The IRS concluded the “Protect Your Clients; Protect Yourself” summer campaign, which encouraged tax professionals to implement robust security measures to defend against identity theft and emerging data security threats. The campaign highlighted the critical need to protect sensitive information from cybercriminal exploitation.

August 27, 2024: The IRS reminded truckers that the deadline to file IRS Form 22901, Heavy Highway Vehicle Use Tax Return, and pay the heavy highway vehicle use tax for 2024 is September 3, 2024.

August 27, 2024: The IRS encouraged taxpayers to conduct a tax checkup at the end of the summer to adjust their withholding or payments and prevent unexpected tax bills next year. This initiative aims to help taxpayers align their tax payments with what they owe, especially those with gig economy jobs or other income not subject to withholding.

August 28, 2024: The IRS notified employers that they can use educational assistance programs to help employees repay their student loans through December 31, 2025.

August 28, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in the US Virgin Islands that were affected by Tropical Storm Ernesto. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency, including individuals and households that reside or have a business in any of the [...]

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Weekly IRS Roundup August 19 – August 23, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Sep 3, 2024 | IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19, 2024 – August 23, 2024.

August 19, 2024: The IRS released Internal Revenue Bulletin 2024-34, which includes the following:

Treasury Decision 10005, which provides the criteria for single-employer defined benefit plan sponsors to obtain approval to use plan-specific mortality tables when calculating present value for minimum funding. Effective July 31, 2024, these changes will apply to plan years beginning on or after January 1, 2025.
Notice 2024-61, which provides the inflation adjustment factor and phase-out amount for the enhanced oil recovery credit under § 38 of the Internal Revenue Code (Code) for calendar years 1991 through 2024.
Announcement 2024-31, which revokes the Code § 501(c)(3) determination for specified organizations and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).

August 19, 2024: The IRS reminded taxpayers that summer day camp expenses may qualify for the Child and Dependent Care tax credit, which can help offset costs for working parents with children under 13. The credit may cover up to 35% of qualifying expenses, with a maximum eligible expense of $3,000 for one child and $6,000 for two or more.

August 19, 2024: The IRS released Notice 2024-63, which allows employers to match contributions to Code § 401(k) plans and similar retirement plans based on employees’ student loan payments. This guidance, effective for plan years beginning after December 31, 2023, includes eligibility criteria, employee certification requirements, and special nondiscrimination testing relief.

August 19, 2024: The IRS reminded taxpayers who requested an extension to file their federal taxes that free filing options, such as IRS Free File and MilTax (for eligible military members), are still available for filing electronically and claiming tax credits.

August 20, 2024: The IRS advised taxpayers who opted for paid tax preparers to help file their tax returns to verify the preparer’s credentials, check their history with the Better Business Bureau, and ensure they offer IRS e-file services.

August 20, 2024: The IRS highlighted the “Security Six,” a set of essential steps tax professionals can take to protect their offices, computers, and client data from cyber threats. These steps include using anti-virus software, firewalls, multifactor authentication, backup software or services, encrypted drives, and virtual private networks.

August 21, 2024: The IRS reminded school teachers that they can deduct up to $300 of unreimbursed classroom expenses for the 2024 tax year. This deduction applies to a variety of classroom items, including supplies, books, and equipment, and is available even if teachers take the standard deduction.

August 21, 2024: The IRS released Revenue Ruling 2024-18, which announces that interest rates for tax overpayments and underpayments under Code § 6621 will remain unchanged for the fourth [...]

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Weekly IRS Roundup August 12 – August 16, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Aug 22, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 12, 2024 – August 16, 2024.

August 12, 2024: The IRS released Internal Revenue Bulletin 2024-33, which includes final regulations on the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving foreign corporations under Section 367 of the Internal Revenue Code. These regulations, effective July 17, 2024, also cover the consequences for recipients of such stock or securities and subsequent inbound nonrecognition transactions.

August 12, 2024: The IRS reminded taxpayers of the option to electronically request relief for certain late-filed international documents, such as gain recognition agreements and dual consolidated losses, using eFax. This digital option, introduced in August 2023, aims to streamline the process and reduce the burden of paper documentation.

August 12, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Minnesota that were affected by severe weather that began on June 16, 2024. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency (FEMA), including individuals and households that reside or have a business in Blue Earth County or one of the other 24 specified Minnesota counties.

August 13, 2024: The IRS released an updated Written Information Security Plan (WISP) to help tax professionals protect against identity theft and data breaches. As part of the Protect Your Clients; Protect Yourself campaign, WISP highlights best practices like multifactor authentication and mandatory reporting of security incidents affecting more than 500 individuals.

August 13, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Vermont that were affected by Hurricane Debby. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by FEMA, including individuals and households that reside or have a business in any of the 14 Vermont counties.

August 14, 2024: The IRS encouraged qualifying businesses, tax-exempt organizations and government entities to complete pre-filing registration for elective pay related to 2023 projects at least 120 days before they file their tax returns. By registering, taxpayers can earn certain tax credits under the Inflation Reduction Act of 2022 and the CHIPS and Science Act.

August 15, 2024: The IRS announced the opening of the application period for the 2025 Compliance Assurance Process program, which will run from September 4, 2024, to October 31, 2024. This program is available to certain privately held C corporations and publicly traded corporations with at least $10 million in assets.

August 15, 2024: The IRS reminded truckers that the deadline to file IRS Form 2290, Heavy Highway [...]

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Weekly IRS Roundup August 5 – August 9, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Aug 16, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5, 2024 – August 9, 2024.

August 5, 2024: The IRS released Internal Revenue Bulletin 2024-32, which includes final regulations on the excise tax for certain sales by manufacturers, producers and importers of designated drugs under Internal Revenue Code § 5000D. Effective August 5, 2024, these regulations offer comprehensive guidance on the quarterly reporting and payment of the excise tax.

August 5, 2024: The IRS reminded educators working at least 900 hours in a school year that they may qualify for the Educator Expense Deduction, which allows them to deduct unreimbursed expenses for classroom supplies, technology and training from their taxes.

August 6, 2024: The IRS alerted taxpayers about the American opportunity tax credit and the lifetime learning credit, which help offset education costs for post-high school coursework. To claim these credits, taxpayers must complete IRS Form 8863 and meet specific eligibility requirements.

August 6, 2024: The IRS reminded tax professionals that they must use multifactor authentication to safeguard clients’ sensitive information in accordance with the Federal Trade Commission’s safeguards rule. This measure, effective as of June 2023, aims to enhance account security and reduce the risk of data breaches.

August 7, 2024: The IRS released statistics on the Inflation Reduction Act of 2022’s clean energy tax credits for tax year 2023, which show that taxpayers claimed significant amounts in residential clean energy and energy-efficient home improvement credits. These credits cover investments in solar electricity, solar water heating, battery storage, heat pumps, efficient air conditioners, insulation, windows and doors.

August 7, 2024: The IRS notified taxpayers that employer-offered educational assistance programs can help employees pay for college expenses, including tuition, books, supplies and student loan payments.

August 8, 2024: The IRS announced it will accelerate the processing of Employee Retention Credit claims while intensifying audits and investigations to prevent improper payments.

August 9, 2024: The IRS released an early draft of the updated IRS Form 1099-DA for brokers to use in 2025 to report digital asset transactions. This draft reflects the final regulations and related guidance for custodial broker reporting and includes transitional relief measures.

August 9, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in South Carolina, North Carolina, Florida and Georgia that were affected by Hurricane Debby. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency, including individuals and households that reside or have a business in all counties in South Carolina and select counties in Georgia, Florida and North Carolina.

August 9, 2024: The IRS released its weekly list of written determinations (e.g., Private [...]

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Weekly IRS Roundup July 29 – August 2, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Aug 8, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 29, 2024 – August 2, 2024.

July 29, 2024: The IRS released Internal Revenue Bulletin 2024-31, which includes the following:

Revenue Procedure 2024-27, which provides new reproduction requirements for substitute forms, including Forms W-2 and W-3, for wages paid during the 2024 calendar year. These guidelines specify how substitute forms must be prepared and used to ensure they meet IRS and Social Security Administration standards.
Proposed Regulations, which provide that interest on overpayments under § 6611 of the Internal Revenue Code (Code) that is applied to erroneous employment tax credit refunds will be treated as an underpayment of tax. The regulations are expected to impact businesses, tax-exempt organizations and certain governmental entities that claimed refundable credits under the Families First Coronavirus Response Act; the Coronavirus Aid, Relief, and Economic Security Act; and the American Rescue Plan Act of 2021.
Proposed Regulations, which allow the IRS to directly accept tax payments by credit or debit card, eliminating the need for third-party payment processors.

July 29, 2024: The IRS celebrated National Whistleblower Day by recognizing the contributions of whistleblowers in support of tax compliance efforts.

July 29, 2024: The IRS warned taxpayers to stay alert for scammers impersonating the IRS through fraudulent calls, emails, texts, and social media messages and reminded taxpayers that it will never initiate contact via these methods to request personal or financial information.

July 30, 2024: The IRS encouraged the use of Identity Protection PINs and IRS online accounts to safeguard against tax-related identity theft and provide an extra layer of security for taxpayers and tax professionals.

July 30, 2024: The IRS encouraged taxpayers to follow IRS-verified social media accounts and subscribe to e-news services for accurate tax information and updates and to avoid misinformation and scams.

July 31, 2024: The IRS released Revenue Procedure 2024-32, which outlines the procedures for defined benefit plans sponsors subject to funding requirements under Code § 430 to request approval for using plan-specific substitute mortality tables for plan years beginning on or after January 1, 2025.

August 1, 2024: The IRS reminded taxpayers that their privacy is a fundamental right safeguarded by the Taxpayer Bill of Rights and that all IRS actions will adhere to legal standards.

August 2, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges

by Timothy S. Shuman, Susan E. Ryba, Parisa M. Griess and Samuel J. Preston | Jul 10, 2024 | Court Procedure Matters

On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a pillar of US administrative law for four decades, required courts to defer to an agency’s reasonable interpretation of an ambiguous statute even where the court concluded that a different interpretation was better supported.

By ending the Chevron doctrine, Loper Bright has created new opportunities for taxpayers to challenge federal tax regulations. While taxpayers have long challenged federal tax regulations, Chevron’s deferential regime hampered many challenges to tax regulations because where there was statutory ambiguity or silence, courts generally deferred to agency interpretations. Loper Bright has evened the playing field between taxpayers and agencies because now both must convince courts that their interpretation of the statute is the best interpretation.

Weekly IRS Roundup June 17 – June 21, 2024

by Evan Walters, Kevin Spencer and Sama Kaseer | Jun 27, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17, 2024 – June 21, 2024.

June 17, 2024: The IRS released Internal Revenue Bulletin 2024-25, which includes the following:

Revenue Ruling 2024-12, which provides the June 2024 applicable federal rates.
Treasury Decision 9993, which provides final regulations on the election under Internal Revenue Code (Code) 6418 to transfer eligible energy credits, effective July 1, 2024.
Treasury Decision 9997, which reduces the cost of applying for or renewing a preparer tax identification number from $21 to $11.
Proposed Regulations, which would remove the “associated property rule” and related rules from the regulations on interest capitalization requirements for improvements to “designated property” under Code 263A(f) and clarify the definition of “improvement” in the existing regulations.

June 17, 2024: The IRS announced the establishment of a new dedicated group within the Office of Chief Counsel that will focus on developing guidance for partnerships, specifically with respect to the use of “basis shifting” transactions by related-party partnerships.

June 17, 2024: The IRS released guidance intended to target certain transactions that use the basis adjustment provisions in Code §§ 734, 743, 754 and 755 to shift basis to depreciable property through partnership transactions. This guidance includes:

Revenue Ruling 2024-14, which identifies three types of basis shifting transactions involving related parties that, according to the IRS, should be disallowed for lack of economic substance.
Notice 2024-54, which announces the IRS’s intent to propose regulations under Code §§ 732, 734, 743 and 755 that, if finalized, are intended to take effect on or after June 17, 2024. The regulations would identify several types of “covered transactions” in which basis step-ups resulting from partnership transactions would be disallowed. Unlike Revenue Ruling 2024-14, these regulations would not depend on a covered transaction lacking economic substance.
Proposed Regulation § 1.6011-18, which would identify certain partnership basis shifting transactions as “transactions of interest,” which generally must be disclosed to the IRS.

June 17, 2024: The IRS provided general tips for taxpayers benefiting from educational assistance programs under Code § 127 with respect to the treatment of certain educational expenses, qualified education loans and working condition fringe benefits.

June 17, 2024: The IRS released Notice 2024-53, which provides the 24-month average corporate bond segment rates for June 2024, yield curve and segment rates for single-employer plans and 30-year Treasury securities interest rates.

June 18, 2024: The IRS announced the release of final regulations for taxpayers who satisfy certain prevailing wage and apprenticeship (PWA) requirements regarding the construction, alteration or repair of certain clean energy facilities or properties, projects or equipment. Taxpayers who satisfy these PWA requirements are eligible for increased credit or deduction amounts for certain clean energy [...]

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Weekly IRS Roundup June 10 – June 14, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Jun 25, 2024 | IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 10, 2024 – June 14, 2024.

June 10, 2024: The IRS released Internal Revenue Bulletin 2024-24, which includes the following:

Revenue Ruling 2024-11, which provides the interest rates under 6621 of the Internal Revenue Code (Code) for tax underpayments and overpayments for the calendar quarter beginning July 1, 2024. The underpayment and overpayment interest rates will remain the same for the third calendar quarter of 2024.
Notice 2024-36, which provides the timeline for the second 2024 allocation round of the Qualifying Advanced Energy Project Credit program under Code 48C(e) and supersedes Appendices A, B and C of Notice 2023-44.
Notice 2024-39, which provides the inflation adjustment factor for the carbon oxide sequestration credit under Code § 45Q for taxpayers who make an election under § 45Q(b)(3) for calendar year 2024.
Notice 2024-40, which updates the corporate bond weighted average interest rate for plan years beginning May 2024, the 24-month average segment rates, the funding transitional segment rates applicable for May 2024 and the minimum present value transitional rates for April 2024.
Notice 2024-41, which provides a new elective safe harbor for taxpayers seeking to qualify their energy projects for the 10% Domestic Content Bonus Credit. The notice also modifies Notice 2023-38 by expanding the list of Applicable Projects to include hydropower and pumped hydropower storage facilities, among other changes.
Proposed Regulations, which provide guidance on information reporting requirements for transactions with foreign trusts and the receipt of large foreign gifts under Code § 643(i), 679, 6039F, 6048 and 6677 (the foreign trust and gift provisions). The proposed regulations would also provide that certain loans from a foreign trust and the use of trust property are reportable events.
Announcement 2024-22 and Announcement 2024-23, which revoke the Code § 501(c)(3) determination for specified organizations and stipulate that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).
Announcement 2024-24, which notifies taxpayers of the applicable Reference Standard 90.1 required under Code § 179D(c)(2) as part of the definition of energy efficient commercial building property, effective May 17, 2024.

June 10, 2024: The IRS highlighted options for taxpayers who missed the April filing deadline to file their 2023 federal income tax returns and reminded those taxpayers to pay the amounts owed as soon as possible to limit penalties and interest charges.

June 10, 2024: The IRS reminded taxpayers that the second quarter estimated tax payment deadline is June 17, 2024.

June 10, 2024: The IRS advised that most individual and business taxpayers can use the Online Payment Agreement service to set up a payment plan, including an installment agreement, to pay off an [...]

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Weekly IRS Roundup June 3 – June 7, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Jun 13, 2024 | IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3, 2024 – June 7, 2024.

June 3, 2024: The IRS released Internal Revenue Bulletin 2024-23, which includes Revenue Procedure 2024-23. The revenue procedure provides an updated list of tax accounting method changes for which IRS consent will be automatically granted pursuant to Form 3115, Application for Change in Accounting Method.

June 5, 2024: The IRS announced it has accepted more than one million taxpayer submissions via the Document Upload Tool since it launched in 2021. The Document Upload Tool enables taxpayers and tax professionals to securely upload required tax documents online at IRS.gov.

June 5, 2024: The IRS outlined factors to help taxpayers distinguish hobbies from true business activities and reminded them that payments received for goods and services through payment apps, such as Cash App and Venmo, are taxable income.

June 5, 2024: The IRS issued Notice 2024-46, which provides that payments made by Norfolk Southern to individuals affected by the 2023 train derailment incident in East Palestine, Ohio, are considered “qualified disaster relief payments,” which should be excluded from gross income if they are not otherwise covered by insurance.

June 6, 2024: The IRS announced that eligible contractors who build new energy efficient homes or substantially reconstruct existing homes into qualified energy efficient homes may be eligible for a tax credit of up to $5,000 per home. The credit amount depends on the type of home, the home’s energy efficiency and the date the home was purchased or leased.

June 7, 2024: The IRS issued Notice 2024-48, which provides the requirements for qualifying under the Statistical Area Category or the Coal Closure Category in Notice 2023-29 to determine taxpayers’ eligibility for the Energy Community Bonus Credit amounts or rates under Internal Revenue Code (Code) §§ 45, 45Y, 48 and 48E.

June 7, 2024: The IRS issued Revenue Procedure 2024-26, which provides additional procedures for qualified manufacturers of new clean vehicles to submit records demonstrating their compliance with certain requirements under Code §§ 30D(d) and (e) to be eligible for the clean vehicle tax credit.

June 7, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Kentucky that were affected by severe weather that started April 2, 2024. The new deadline is November 1, 2024. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency (FEMA), including individuals and households that reside or have a business in the following counties: Boyd, Carter, Fayette, Greenup, Henry, Jefferson, Jessamine, Mason, Oldham, Union and Whitley.

June 7, 2024: The IRS extended the deadline to file federal individual and business tax returns and make [...]

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