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Table of Contents

• ↓ I. Introduction
• ↓ II. The Beard Test: Doctrinal Origins and Development
• ↓ III. The Recently Released IRS Communication: Application to Partnership Returns
• ↓ IV. Practical Implications for Tax Practitioners
• ↓ V. Distinguishing Beard from the Present Context
• ↓ VI. Conclusion
• ↓ Top Alternatives to currentfederaltaxdevelopments.com

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"A site devoted to articles on current developments in federal taxes geared toward CPAs in tax practice."

"Pellegrino v. United States, No. 1:26-cv-00403, 2026 WL (Fed. Cl. Aug. 20, 2026)"

"In Pellegrino v. United States, No. 1:26-cv-00403 (Fed. Cl. Aug. 20, 2026), Judge Philip S. Hadji of the United States Court of Federal Claims addressed a pro se tax refund action that, while ultimately dismissed on jurisdictional grounds, raises several issues of practical significance for tax professionals who advise clients on refund claims, withholding credits, and the evidentiary standards governing Forms 1099-B and 1099-MISC."

"Plaintiff Mark Pellegrino alleged that he filed his individual income tax return for tax year 2024 in April 2025, submitting a Form 1040, a Schedule C for Mark Pellegrino LLC (a real estate business), a Form 8949 reporting two short-term transactions, and a Schedule D summarizing those transactions. The Form 1040 reported $0 in wages, the standard deduction, and $48,220 in federal tax withheld. The Schedule C reflected $110,417 in gross income and $85,000 in total expenses for the LLC, yielding $25,417 in tentative profit. The Form 8949 included two transactions described as “Real Money Monitized [sic],” one with cost and proceeds of $42,000 and another with cost and proceeds of $66,500, producing neither capital gains nor losses."

Key Topics & Focus Areas for currentfederaltaxdevelopments.com:

I. Introduction

II. The Beard Test: Doctrinal Origins and Development

III. The Recently Released IRS Communication: Application to Partnership Returns

IV. Practical Implications for Tax Practitioners

V. Distinguishing Beard from the Present Context

VI. Conclusion