A county in Michigan was owed about $2,200 in back taxes. To collect it, the government took a home worth close to $200,000, auctioned it for a fraction of that, and called the matter settled. The family is now putting a simple question to the Supreme Court: when the state sells your house over a small debt, does it owe you the real worth of what it took or only whatever the auction happened to fetch?
The Rule that is Already on the Books
Three years ago, the court drew a clear line. Geraldine Tyler, then in her 90s, had let a $2,311 levy on a Minneapolis condo balloon to about $15,000 once penalties and interest stacked up. Hennepin County took the unit, found a buyer at $40,000, and held onto all of it. By any fair reckoning, the $25,000 above her debt was Tyler’s money – even though the county walked away with it. Minnesota law blessed that, as did 11 other states and the District of Columbia, plus nine more states under narrower terms.
A unanimous court ended the practice. Chief Justice Roberts wrote that a government can sell property to satisfy a tax debt but cannot help itself to more than the debt is worth. Leftover equity belongs to the owner, and a state cannot dodge that by defining the property interest away.
The Question Tyler Left Hanging
Tyler was tidy because the surplus was undeniable. Subtract a debt near $15,000 from a $40,000 sale, and the leftover is beyond dispute. The justices never had to confront the messier case where the sale price itself is artificially low. If a forced auction brings in far less than a home would fetch on the open market, is that depressed number really the measure of what the owner lost?
That is the gap, and tax auctions are where it opens. Unlike an ordinary listing, these sales draw a thin crowd of investors and speculators, and the government has little reason to chase top dollar. A county could therefore obey Tyler to the letter, hand back every cent of the auction surplus, and still watch most of a family’s equity vanish.
How the Pung Family Got Here
Three-and-a-half decades ago, Timothy Scott Pung paid $125,000 for a roughly 3,000-square-foot house in Isabella County, and for years it carried Michigan’s Principal Residence Exemption. Scott died in 2004, and his wife in 2008. Their son Marc stayed on, assuming the exemption rolled forward without any new filing. The assessor saw it otherwise and stripped the break retroactively. Marc fought back, and a state tax tribunal agreed no further paperwork had ever been required.
The assessor would not let it go. Over a shortfall of $2,241.93, on a place the county itself pegged at $194,400, the family was thrown out, and the home went under the hammer for $76,000. Nobody disputes that the estate is owed the surplus. The quarrel is how to measure it. Isabella County treats the surplus as the hammer price minus the debt, leaving about $74,000. The estate says the yardstick should be the home’s true market value minus the debt, pushing the number toward $194,400. The spread tops $100,000.
Bigger Than One House
The stakes reach far past Michigan. Minnesota alone moved more than 4,300 properties through these sales between 2014 and 2020. Across the 1,200-plus that were family homes, the typical owner lost some 92 percent of the equity above the debt, averaging around $207,000 against bills averaging just $17,000. In the nation’s capital, a veteran with dementia lost a $200,000 home over $133.88.
There is a second front, too. The estate contends the foreclosure worked as an excessive fine barred by the Eighth Amendment, a theory the lower court waved off as ordinary tax collection but one that Justices Gorsuch and Jackson have flagged for review.
Argument wrapped on Feb. 25 with a ruling likely any day now. The court has already said the government cannot keep more than it is owed. Now it must decide whether that shield covers only the cash left after the gavel, or the equity that vanished before.
Alan F Burke CPA
Supreme Court Will Decide What Homeowners Are Owed When Tax Sale Erases Equity
July 1, 2026 · Blog, Tax and Financial News
⏱ 4 min read
A county in Michigan was owed about $2,200 in back taxes. To collect it, the government took a home worth close to $200,000, auctioned it for a fraction of that, and called the matter settled. The family is now putting a simple question to the Supreme Court: when the state sells your house over a small debt, does it owe you the real worth of what it took or only whatever the auction happened to fetch?
The Rule that is Already on the Books
Three years ago, the court drew a clear line. Geraldine Tyler, then in her 90s, had let a $2,311 levy on a Minneapolis condo balloon to about $15,000 once penalties and interest stacked up. Hennepin County took the unit, found a buyer at $40,000, and held onto all of it. By any fair reckoning, the $25,000 above her debt was Tyler’s money – even though the county walked away with it. Minnesota law blessed that, as did 11 other states and the District of Columbia, plus nine more states under narrower terms.
A unanimous court ended the practice. Chief Justice Roberts wrote that a government can sell property to satisfy a tax debt but cannot help itself to more than the debt is worth. Leftover equity belongs to the owner, and a state cannot dodge that by defining the property interest away.
The Question Tyler Left Hanging
Tyler was tidy because the surplus was undeniable. Subtract a debt near $15,000 from a $40,000 sale, and the leftover is beyond dispute. The justices never had to confront the messier case where the sale price itself is artificially low. If a forced auction brings in far less than a home would fetch on the open market, is that depressed number really the measure of what the owner lost?
That is the gap, and tax auctions are where it opens. Unlike an ordinary listing, these sales draw a thin crowd of investors and speculators, and the government has little reason to chase top dollar. A county could therefore obey Tyler to the letter, hand back every cent of the auction surplus, and still watch most of a family’s equity vanish.
How the Pung Family Got Here
Three-and-a-half decades ago, Timothy Scott Pung paid $125,000 for a roughly 3,000-square-foot house in Isabella County, and for years it carried Michigan’s Principal Residence Exemption. Scott died in 2004, and his wife in 2008. Their son Marc stayed on, assuming the exemption rolled forward without any new filing. The assessor saw it otherwise and stripped the break retroactively. Marc fought back, and a state tax tribunal agreed no further paperwork had ever been required.
The assessor would not let it go. Over a shortfall of $2,241.93, on a place the county itself pegged at $194,400, the family was thrown out, and the home went under the hammer for $76,000. Nobody disputes that the estate is owed the surplus. The quarrel is how to measure it. Isabella County treats the surplus as the hammer price minus the debt, leaving about $74,000. The estate says the yardstick should be the home’s true market value minus the debt, pushing the number toward $194,400. The spread tops $100,000.
Bigger Than One House
The stakes reach far past Michigan. Minnesota alone moved more than 4,300 properties through these sales between 2014 and 2020. Across the 1,200-plus that were family homes, the typical owner lost some 92 percent of the equity above the debt, averaging around $207,000 against bills averaging just $17,000. In the nation’s capital, a veteran with dementia lost a $200,000 home over $133.88.
There is a second front, too. The estate contends the foreclosure worked as an excessive fine barred by the Eighth Amendment, a theory the lower court waved off as ordinary tax collection but one that Justices Gorsuch and Jackson have flagged for review.
Argument wrapped on Feb. 25 with a ruling likely any day now. The court has already said the government cannot keep more than it is owed. Now it must decide whether that shield covers only the cash left after the gavel, or the equity that vanished before.
Disclaimer
These articles provide general information on tax, accounting, and financial topics for small businesses and individuals. They are educational in nature and are not specific legal, accounting, financial, tax, or other professional advice, and should not be relied upon as such. This content was prepared by Service2Client and may have been reviewed or edited by the website owner for accuracy and compliance. Look for a trust mark below for verification details. No representation is made that any approach described will achieve a particular result, and no regulatory or professional body has reviewed or endorsed this content. Because each situation is different, readers should consult a qualified professional about their specific circumstances before acting. Images accompanying these articles are protected by copyright and may not be copied or reused.
When it comes to the latest report for March 2026 manufactured goods orders, according to the United States Census Bureau’s May 4 report, the government agency reported a 1.5 percent bump in orders for the nation’s manufacturers, growing to $630.4 billion. Understanding concepts like Cost of Goods Manufactured (COGM) is essential to smooth operations.
The cost of goods manufactured (COGM) reflects the total manufacturing costs a company incurs during a particular accounting period to complete goods. It includes direct materials used, direct labor, and manufacturing overhead. COGM helps businesses manage inventory levels and serves as a key input for calculating the cost of goods sold (COGS) reported on the income statement.
The first step is to analyze how each input contributes to the result. This involves reviewing direct materials, direct labor, and overhead to determine the complete production costs for the accounting period. By evaluating each component’s contribution, companies can better project manufacturing capacity and cost-effectiveness.
Direct Materials Used in Production
Direct Materials Used = Beginning Raw Materials Inventory + Purchase of Raw Materials – Ending Raw Materials Inventory
This amount is then incorporated into the Total Manufacturing Costs (and ultimately the WIP inventory) shown above.
Calculating Direct Labor and Manufacturing Overhead:
Direct labor costs are determined from time logs or clock-ins (hours worked × hourly rate). Manufacturing overhead includes indirect production costs such as factory utilities, depreciation, and supervision.
Translating COGM to Cost of Goods Sold:
Once calculated, COGM is transferred to the Finished Goods Inventory account. Finished Goods Inventory consists of completed products ready for sale to customers. The standard relationship is:
COGM shows whether production costs are too high or too low relative to sales. For example, if one business generates $2,000,000 in revenue with $1,500,000 in COGS (25% gross margin), while another has $1,500,000 in revenue but only $750,000 in COGS (50% gross margin), the second company demonstrates stronger profitability.
Understanding COGM enables businesses to optimize costs related to labor, overhead, and materials, ultimately improving net income and operational efficiency. When calculating and reporting COGM, it is essential for businesses to apply these concepts accurately in their accounting and bookkeeping practices.
Alan F Burke CPA
Understanding Cost of Goods Manufactured
June 1, 2026 · Accounting News, Blog
⏱ 3 min read
When it comes to the latest report for March 2026 manufactured goods orders, according to the United States Census Bureau’s May 4 report, the government agency reported a 1.5 percent bump in orders for the nation’s manufacturers, growing to $630.4 billion. Understanding concepts like Cost of Goods Manufactured (COGM) is essential to smooth operations.
The cost of goods manufactured (COGM) reflects the total manufacturing costs a company incurs during a particular accounting period to complete goods. It includes direct materials used, direct labor, and manufacturing overhead. COGM helps businesses manage inventory levels and serves as a key input for calculating the cost of goods sold (COGS) reported on the income statement.
The first step is to analyze how each input contributes to the result. This involves reviewing direct materials, direct labor, and overhead to determine the complete production costs for the accounting period. By evaluating each component’s contribution, companies can better project manufacturing capacity and cost-effectiveness.
Direct Materials Used in Production
Direct Materials Used = Beginning Raw Materials Inventory + Purchase of Raw Materials – Ending Raw Materials Inventory
This amount is then incorporated into the Total Manufacturing Costs (and ultimately the WIP inventory) shown above.
Calculating Direct Labor and Manufacturing Overhead:
Direct labor costs are determined from time logs or clock-ins (hours worked × hourly rate). Manufacturing overhead includes indirect production costs such as factory utilities, depreciation, and supervision.
Translating COGM to Cost of Goods Sold:
Once calculated, COGM is transferred to the Finished Goods Inventory account. Finished Goods Inventory consists of completed products ready for sale to customers. The standard relationship is:
COGM shows whether production costs are too high or too low relative to sales. For example, if one business generates $2,000,000 in revenue with $1,500,000 in COGS (25% gross margin), while another has $1,500,000 in revenue but only $750,000 in COGS (50% gross margin), the second company demonstrates stronger profitability.
Understanding COGM enables businesses to optimize costs related to labor, overhead, and materials, ultimately improving net income and operational efficiency. When calculating and reporting COGM, it is essential for businesses to apply these concepts accurately in their accounting and bookkeeping practices.
Disclaimer
These articles provide general information on tax, accounting, and financial topics for small businesses and individuals. They are educational in nature and are not specific legal, accounting, financial, tax, or other professional advice, and should not be relied upon as such. This content was prepared by Service2Client and may have been reviewed or edited by the website owner for accuracy and compliance. Look for a trust mark below for verification details. No representation is made that any approach described will achieve a particular result, and no regulatory or professional body has reviewed or endorsed this content. Because each situation is different, readers should consult a qualified professional about their specific circumstances before acting. Images accompanying these articles are protected by copyright and may not be copied or reused.
S.98: Rural Broadband Protection Act of 2025 – This bipartisan bill instructs the Federal Communications Commission (FCC) to establish a vetting process for service provider applicants applying for federal funding assistance for broadband deployment in high-cost areas, including rural communities. Sponsored by Sen. Shelley Moore Capito (R-WV) on Jan. 15, 2025, the bill passed in the Senate on June 26, 2025, and in the House on April 20, 2025. It was signed into law by the president on May 11, 2026.
S.723: Tribal Trust Land Homeownership Act of 2025 – Introduced by Sen. John Thune (R-SD) on Feb. 25, 2025, this bill requires the Bureau of Indian Affairs to complete the processing of all residential and business mortgages on Indian land by certain deadlines. It passed in the Senate on Dec. 11, 2025, in the House on March 4, and was enacted on May 4.
A joint resolution to direct the removal of United States Armed Forces from hostilities within or against the Islamic Republic of Iran that have not been authorized by Congress (SJ Res 185) – Well past the 60-day deadline for a president to legally engage in military hostilities abroad without congressional authorization, Sen. Tim Kaine (D-VA) introduced his resolution on April 27. The resolution would remove U.S. military troops from Iran unless explicitly authorized by Congress. On May 19, the resolution narrowly passed in the Senate Foreign Relations Committee, now moving to the Senate floor for debate and a full vote. The resolution faces an uphill battle in the House. However, even if the joint resolution cleared the Senate and the House, it is expected to be vetoed by the president and would require a two-thirds supermajority by both the Senate and the House to override the veto – which is unlikely at this point.
21st Century ROAD to Housing Act (HR 6644) – This bipartisan, White House-endorsed bill addresses housing affordability by placing ownership restrictions on large institutional investors and expanding available financing for homebuyers. One provision would prohibit institutional investors/private equity firms that own more than 350 single-family homes from purchasing additional single-family homes – unless they are sold to individual homeowners after seven years. The act would impose a penalty of up to $1 million per violation or three times the purchase price of the property, whichever is greater. Other provisions waive regulations on community banks to help expand local lending. The bill was introduced by Rep. French Hill (R-AR) on Dec. 11, 2025. It passed in the House on Feb. 9, in the Senate with changes on March 12, and in the House again with changes on May 20. The bill is currently under consideration in the Senate for the second time.
Alan F Burke CPA
Advancing Broadband, Tribal Land Mortgages and Affordable Single-Owner Housing Opportunities
June 1, 2026 · Blog, Congress at Work
⏱ 3 min read
S.98: Rural Broadband Protection Act of 2025 – This bipartisan bill instructs the Federal Communications Commission (FCC) to establish a vetting process for service provider applicants applying for federal funding assistance for broadband deployment in high-cost areas, including rural communities. Sponsored by Sen. Shelley Moore Capito (R-WV) on Jan. 15, 2025, the bill passed in the Senate on June 26, 2025, and in the House on April 20, 2025. It was signed into law by the president on May 11, 2026.
S.723: Tribal Trust Land Homeownership Act of 2025 – Introduced by Sen. John Thune (R-SD) on Feb. 25, 2025, this bill requires the Bureau of Indian Affairs to complete the processing of all residential and business mortgages on Indian land by certain deadlines. It passed in the Senate on Dec. 11, 2025, in the House on March 4, and was enacted on May 4.
A joint resolution to direct the removal of United States Armed Forces from hostilities within or against the Islamic Republic of Iran that have not been authorized by Congress (SJ Res 185) – Well past the 60-day deadline for a president to legally engage in military hostilities abroad without congressional authorization, Sen. Tim Kaine (D-VA) introduced his resolution on April 27. The resolution would remove U.S. military troops from Iran unless explicitly authorized by Congress. On May 19, the resolution narrowly passed in the Senate Foreign Relations Committee, now moving to the Senate floor for debate and a full vote. The resolution faces an uphill battle in the House. However, even if the joint resolution cleared the Senate and the House, it is expected to be vetoed by the president and would require a two-thirds supermajority by both the Senate and the House to override the veto – which is unlikely at this point.
21st Century ROAD to Housing Act (HR 6644) – This bipartisan, White House-endorsed bill addresses housing affordability by placing ownership restrictions on large institutional investors and expanding available financing for homebuyers. One provision would prohibit institutional investors/private equity firms that own more than 350 single-family homes from purchasing additional single-family homes – unless they are sold to individual homeowners after seven years. The act would impose a penalty of up to $1 million per violation or three times the purchase price of the property, whichever is greater. Other provisions waive regulations on community banks to help expand local lending. The bill was introduced by Rep. French Hill (R-AR) on Dec. 11, 2025. It passed in the House on Feb. 9, in the Senate with changes on March 12, and in the House again with changes on May 20. The bill is currently under consideration in the Senate for the second time.
Disclaimer
These articles provide general information on tax, accounting, and financial topics for small businesses and individuals. They are educational in nature and are not specific legal, accounting, financial, tax, or other professional advice, and should not be relied upon as such. This content was prepared by Service2Client and may have been reviewed or edited by the website owner for accuracy and compliance. Look for a trust mark below for verification details. No representation is made that any approach described will achieve a particular result, and no regulatory or professional body has reviewed or endorsed this content. Because each situation is different, readers should consult a qualified professional about their specific circumstances before acting. Images accompanying these articles are protected by copyright and may not be copied or reused.