2026-09-07 IRS Bit By Not Mailing Via Certified Mail

Federal tax developments this week center on significant judicial rulings and regulatory updates impacting tax practice. The Federal Circuit’s decisions in *Bruyere* and *Christensen* confirm that treaty-based foreign tax credits cannot offset the Net Investment Income Tax, while *Goldman v. United States* demonstrates that authorizing professional assistance can inadvertently forfeit financial disability tolling for refund claims. Proposed regulations under Section 1.501(c)(3)-2 seek to codify strict anti-discrimination standards for private schools, effectively prohibiting race-conscious admission and scholarship programs. Additionally, *Wales v. Commissioner* reinforces the IRS's burden to provide Form 3877 to prove certified mailing, preventing the agency from relying on secondary tracking data. Finally, Revenue Procedure 2026-32 introduces automatic accounting method changes for research expenditures and residential construction contracts, providing essential relief for taxpayers navigating recent legislative shifts in these areas.