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  • • Tax Research - Parker Tax Pro Library - In-Depth Tax Analysis November 2024
    • Tax Research Solutions - Parker Tax Publishing Site Map Page 1
    • Tax and Accounting - CPA Client Letters - Parker Tax Pro Library
    • Tax & Accounting Research - Tax Updates November 2024
    • Federal Tax Research Library - Parker's Tax Bulletin - July 8, 2024
    • Professional Tax Research Library - Client Testimonials - Parker Tax Publishing
    • Tax Research Products - Parker Tax Pro Library - Product
    • No Theft Loss Allowed for Taxpayer's "Bad Business Decisions".
    • Ninth Circuit Affirms Tax Court; Advances to a Corporation Were Equity, Not Debt.
    • 401(k) Contribution Limit Increases to $23,500 for 2025; IRA Limit Unchanged at $7,000.
    • Foreign Currency Option Transaction Lacked Profit Motive; Losses Are Not Deductible.
    • IRS Can Adjust Partnership's Outside Basis for Excess Losses from Closed Tax Year.
    • 2024 Year-End Tax Planning for Individuals. Client Letter Included.
    • CPA Sample Client Letter: 2024 Year-End Tax Planning for Individuals.
    • IRS Finalizes Regs on Advanced Manufacturing Production Credit.
    • IRS Issues Final Regs on CHIPS Act Advanced Manufacturing Investment Credit.
    • IRS Updates Guidance on Preventive Care Benefits and Medical Expense Deductions.
    • IRS Announces 2025 Inflation Adjustments; Social Security Benefits Up 2.5% for 2025.
    • Tax Court Holds That Collection Due Process Rules Do Not Apply to FBAR Penalties.
    • Diversion of Trust Fund Taxes Results in Taxable Income to Individual Diverting the Taxes.
    • Proposed Regs Implement IRA Changes to Energy Efficient Home Improvement Credit.
    • IRS Further Postpones Due Dates for Taxpayers Affected by Terroristic Action in Israel.
    • Failure to Attach Power of Attorney to Refund Claim Doesn't Necessarily Doom Filing.
    • Final Regulations Identify Syndicated Conservation Easements as Listed Transactions.
    • Court Rejects Use of Step-Transaction Doctrine to Increase Decedent's Gross Estate.
    • No Deduction Allowed for S Corp's Payments to Government Agency.
    • IRS Announces Annual Per-Diem Guidance for 2024-2025.
    • IRS Fails to Establish Fraud; Adjustments Barred by Statute of Limitations.
    • Electrical Contracting Company Fails to Qualify for Sec. 179D Deduction.
    • IRS Issues Proposed Regs on Alternative Fuel Vehicle Refueling Property Credit.
    • Legal Fees Incurred for Criminal Defense Were Deductible Business Expenses.
    • Ninth Circuit Nixes Use of Pro Rata Method to Allocate Sales Proceeds in Bankruptcy.
    • IRS Requests Comments on Saver's Match Contributions Under SECURE 2.0 Act.
    • Commutation of Residuary Trust Leads to Gift Tax Liability for Decedent's Children.
    • Eleventh Circuit: FBAR Penalties Violated Eighth Amendment's Excessive Fines Clause.
    • IRS Finalizes Regulations on Consistent Basis Reporting Requirement for Estates.
    • Willful Violations of FBAR Include Both Knowing and Reckless Violations.
    • IRS Provides Guidance on Matching Contributions for Student Loan Payments.
    • Tax Court Addresses Mismatched Effective Dates of Two TCJA Foreign Provisions.
    • IRS Modifies Automatic Consent Procedures for Research Expenses Paid in 2022 or 2023.
    • Taxpayers' Schedule C Expenses Denied for Business That Never Began.
    • Tax Court Narrowly Sides with IRS in Rejecting CDP Hearing for Canadian Taxpayer.
    • Ninth Circuit: Untimely Informal Claim Dooms Taxpayers' $700,000 Refund.
    • S Shareholder Is Taxed on Income Stolen from Company by CFO and Corporate Secretary.
    • Sixth Circuit Revives Constitutional Challenge to Crypto Transactions Reporting Rule.
    • IRS Announces Second Employee Retention Credit Voluntary Disclosure Program.
    • Dissipation of Decedent's Assets by Son Justified Jeopardy Assessment.
    • Innocent Spouse Relief Granted to Taxpayer Who Was Not Involved in Husband's Business.
    • IRS Issues Updated Frequently Asked Questions on Clean Vehicle Credits.
    • Tax Court Rejects $22 Million Easement Deduction Based on "Lost Development Rights".
    • Nonresident Alien's Inventory Gain on the Sale of Her Partnership Interest Is Not Taxable.
    • Chief Counsel's Office Addresses Recapture of Excess Credits from Employers Using TPPs.
    • Innocent Spouse Relief Does Not Apply to Liability for an Erroneous Interest Refund.
    • Taxpayers' Carriage House Losses Are Nondeductible Under Passive Loss Rules.
    • Couple's Non-delegable Duty to Timely File Returns Does Not Preclude Suit Against CPAs.
    • Fourth Circuit Affirms Tax Court' s Disallowance of Conservation Easement Deduction.
    • Tax Court: Installment Method Applies to Deferred Gain on Sale of Stock to ESOP.
    • IRS Issues Final and Proposed Regs on Required Minimum Distributions.
    • Fourth Circuit: Biotech Company Overstated Expenses in Computing Research Credit.
    • IRS Issues Final Regulations on Disallowance of Conservation Easement Deductions.
    • IRS Issues Final Regulations and Other Guidance on Digital Asset Transactions.
    • Supreme Court Upholds Mandatory Repatriation Tax on CFC Owners.
    • Supreme Court Overrules Chevron, Opening the Door to Extensive Challenges to Tax Regulations.
    • IRS Issues Final Regulations and Other Guidance on Digital Asset Transactions.
    • Jury Verdict of Reasonable Cause for Late Filing Vacated Due to Flawed Jury Instructions.
    • Court Rejects Injunctive Relief for Tax Prep Business Stripped of Its EFINs.
    • Certain East Palestine Derailment Relief Payments Are Excludable from Income.
    • Prioritizing Travel and a New Business Over Paying Tax Debt Dooms Tax Discharge.
    • Final Regs Issued on Prevailing Wage and Apprenticeship Requirements for Increased Credit Amounts.
    • IRS Guidance Targets Partnership Basis Shifting Transactions Involving Related Parties.
    • Consent Order Signed by Debtor and IRS Does Not Preclude Additional Tax Assessments.
    • Tenth Circuit: Denial of Taxpayer's Motion to Dismiss by Tax Court Cannot Be Appealed.
    • Whistleblower's Info Failed to Meet $2 Million Threshold; Larger Reward Denied.
    • Eleventh Circuit Invalidates Notice Identifying Conservation Easements as Listed Transactions.
    • IRS Issues Proposed Regulations on Clean Electricity Credits.
    • Supreme Court: Estate's Value Includes Insurance Proceeds Used to Redeem Shares.
    • Partnership Did Not Have To Substantiate Assets In Order to Make Valid BBA Election.
    • Widow Can't Recover Litigation Costs After Prevailing on Innocent Spouse Issue.
    • Court Denies Taxpayer's Request to Dismiss Willful FBAR Penalties Case.
    • Taxpayers' Ranching and Ecotourism Losses Can't Be Used to Offset Other Income.
    • Tax Court Rejects IRS's Treatment of Option and Sale Agreements as a Sham Transaction.
    • Termination of Marital Trusts Did Not Result in Gift Tax Liability.
    • Proposed Regs Remove Associated Property Rule From Interest Capitalization Rules.
    • "Funded" Research Precludes Engineering Firm from Taking Research Tax Credits.
    • IRS Issues Final Regulations on Transfers of Energy Credits Under the Inflation Reduction Act.
    • IRS Finalizes Proposed Generation-Skipping Transfer Tax Regulations Proposed in 2008.
    • D.C. Circuit Affirms Penalties for Failing to Report Foreign Bank Accounts.
    • IRS Issues Final Regulations Regarding Clean Vehicle Credits.
    • Tax Court Invalidates Notice of Deficiency Due to IRS Address Change Irregularities.
    • Tax Court Nixes Theft Loss Deduction for Decline in Cash Value of Life Insurance Policies.
    • IRS: 2024 Will Be the Last Transitional Relief Year for Required Minimum Distributions.
    • District Court Rejects Charitable Contribution Workaround to SALT Deduction Cap.
    • Court Denies Arizona's Motion to Enjoin IRS From Taxing State Rebate Payments.
    • Tax Court Finds IRS Lacked Authority to Assess Sec. 6038(b) Penalties.
    • Tax Court Reverses Course on Easement Donations; Holds Proceeds Reg Violates APA.
    • Final Regulations Modify the Definition of Short -Term, Limited-Duration Insurance.
    • Tax Court Invalidates Regulation on Disaster-Related Postponements of Filing Deadlines.
    • Guidance Addresses Tax Treatment of Rebates on Purchases of Energy Efficient Property.
    • Tax Court Improperly Dismissed Taxpayer's CDP Challenge As Moot, Third Circuit Says.
    • Taxpayer Can't Avoid Being a Responsible Person Due to CPA's Embezzlement Scheme.
    • Second Circuit: Jurisdictional Dismissals of Small Tax Cases Cannot Be Appealed.
    • IRS Issues Proposed Regulations on Advance Notice of Third-Party Contacts.
    • Majority of Professor's Stock Sale Does Not Qualify for Preferential Tax Treatment.
    • Proposed Regs Identify Charitable Remainder Annuity Trusts as Listed Transactions.
    • Secretive Husband Who Failed to Share Financial Info Is Solely Liable for Deficiency.
    • Statute of Limitations on Trust Fund Recovery Penalty Was Not Triggered by Filing Form 941.
    • Taxpayer Can't Escape Assessments on Excess IRA Contributions.
    • IRS Issues Final Regs and Other Guidance on Elective Payments of Clean Energy Credits.
    • Taxpayers Hit with Civil Fraud Penalties for Sham Trust Arrangement.
    • Flawed Appraisal Dooms $20 Million Conservation Easement Charitable Deduction.
    • Taxpayer Properly Added Bond Fees to Basis for Purposes of Low-Income Housing Credit.
    • Returns That Omit Estimated Tax Payments Are Not In Processible Form for Purposes of Triggering ...
    • Taxpayer Had Unreported Income Due to Workers' Compensation Offset Rule.
    • Third Party Payers Are Liable for Improperly Claimed Employee Retention Credits.
    • Taxpayer's Refund Request on Amended Return Was Untimely, Court Finds.
    • Taxpayer Constructively Received Early IRA Distribution Due to Criminal Forfeiture.
    • What to Do About Missing or Incorrect Forms W-2 and Forms 1099.
    • Sixth Circuit Holds That the Willful FBAR Penalty Applies to Reckless Conduct.
    • Option Agreement to Purchase Shares in Family Business Was a Taxable Gift.
    • IRS Issues Annual Vehicle Depreciation and Lease Inclusion Amounts for 2024.
    • Tax Court Sides with Taxpayer: Transfers Between S Corps Were Not Debt Transactions.
    • IRS Issues Guidance on the Alternative Fuel Vehicle Refueling Property Credit.
    • Innocent Spouse Claim Nixed by Significant Benefit to Taxpayer from Underpayments.
    • Microcaptive Insurance Arrangement Fails to Pass Muster in Tax Court.
    • House Passes $78 Billion Bipartisan Tax Relief Bill; Separate SALT Relief Bill Introduced.
    • Initial Guidance Provided on Pension-Linked Emergency Savings Accounts.
    • Partnerships Get Additional Time to Provide Complete Forms 8308.
    • January 31 Deadline is Approaching for Forms W-2 and 1099.
    • IRS Reconsiders Gift Tax Consequences of Trust Tax Reimbursement Clauses.
    • Tax Court Petition Mailed By Erroneous Due Date on Notice of Deficiency Was Timely.
    • Transitional Guidance: Digital Assets Should Be Excluded in Determining if Form 8300 Must Be Filed.
    • IRS Updates Guidance on Availability of Exemptions from E-Filing Requirements.
    • Lawmakers Announce Framework for Bipartisan Tax Deal.
    • IRS Modifies Interim Guidance on Amortization of Research Expenditures.
    • Tax Court Allows Estimated Cost of Goods Sold Expense; Upholds Accuracy Related Penalty.
    • IRS Provides Guidance on SECURE 2.0 Act Retirement Plan Changes.
    • Top Tax Developments of 2023.
    • IRS Issues Standard Mileage Rates for 2024.
    • Court Rejects Taxpayer's Argument That IRS Waived Formal Refund Requirements.
    • Settlement Payment for Wrongful Termination Was Not Excludable from Income.
    • IRS Issues Proposed Regs to Implement the Advanced Manufacturing Production Credit.
    • IRS Provides Penalty Relief for Certain Returns Filed During COVID-19 Pandemic.
    • IRS Extends Safe Harbor for Incremental Cost of Commercial Clean Vehicles to 2024.
    • IRS Issues Guidance on Clean Vehicle Credit Excluded Entity Provisions.
    • $700,000 Settlement Payment from Apartment Complex Was Not Excludable from Income.
    • Functional Analysis Determines Limited Partner Status for Self-Employment Tax Purposes.
    • Proposed Regs Address 401(k) Plans for Long-Term Part-Time Employees.
    • Proposed Regs Update Rules on Transactions Between Related Persons and Partnerships.
    • Fifth Circuit Affirms Denial of Construction Contractor's Claims for Research Credits.
    • Proposed Regs Address SECURE 2.0 Act Conservation Contribution Disallowance Rule.
    • Sixth Circuit Vacates District Court's Decision Invalidating Notice 2007-83.
    • Proposed Regs Provide Guidance on Energy Credit.
    • 2023 Year-End Tax Planning for Businesses. Client Letter Included.
    • CPA Sample Client Letter: 2023 Year-End Tax Planning for Businesses.
    • 401(k) Contribution Limit Increases to $23,000 for 2024; IRA Limit is $7,000.
    • Exchange of Variable Contracts Results in $71 Million Short-Term Capital Gain.
    • IRS Announces 2024 Inflation Adjustments.
    • 2023 Year-End Tax Planning for Individuals. Client Letter Included.
    • CPA Sample Client Letter: 2023 Year-End Tax Planning for Individuals.
    • IRS Whistleblower Office Did Not Abuse Discretion in Determining Award Amount.
    • Translation Error Raises Question as to Taxpayer's Willfulness in Failing to File FBAR.
    • Social Security Announces 3.2 Percent Cost of Living Adjustment for 2024.
    • Tax Court Nixes Attempted Rollover of Cash Proceeds from Sale of Partnership Interest.
    • IRS Postpones Deadlines for Taxpayers Affected by Terrorist Attacks in Israel.
    • Court Upholds Validity of Closing Agreement Waiving Foreign Earned Income Exclusion.
    • IRS Extends Replacement Period under Section 1033 for Certain Livestock Sales.
    • Tax Court: 30-Day Deadline to Request CDP Hearing Can Be Equitably Tolled.
    • Real Estate Investor Couldn't Rely on CPA to Excuse Accuracy-Related Penalties.
    • Revenue from Hotel's Operating Fund Was Not Excludable Under Trust Fund Doctrine.
    • Cash Value of Life Insurance Policy Was Taxable Under Split-Dollar Insurance Rules.
    • IRS Provides Guidance on Transfers of Clean Vehicle Credits Beginning in 2024.
    • IRS Updates Wash Sale Rules for Redemptions of Shares in Money Market Funds.
    • Widow Wins Refund of Lien Proceeds Due to Innocent Spouse Relief.
    • Incarcerated Taxpayer Was Not Liable for Misappropriated IRA Distributions.
    • IRS Issues Annual Per-Diem Guidance for 2023-2024.
    • No Supervisory Approval Needed for Assessment of Penalties Under Sec. 6721(e).
    • Federal Circuit: Court of Federal Claims Misapplied Step Transaction Doctrine.
    • IRS Provides Guidance on New Energy Efficient Home Credit.
    • Estate Administrator's Refund Lawsuit Kept Alive by IRS Processing Delays.
    • Plan to Avoid Corporate Tax Through Interest Deductions Doesn't Fly in Tax Court.
    • IRS Properly Referred Case to DOJ Before Rejecting Proposed Installment Agreement.
    • Losses Flowing to S Portion of an ESBT Can Be Carried to Other Years as NOLs.
    • IRS Issues Interim Guidance on Amortization of Research and Experimental Costs.
    • IRS Provides Guidance On Federal Tax Treatment of 2023 State Tax Refunds.
    • Tax Court Vacates Summary Judgment Order Due to Backdated Penalty Approval Form.
    • Tax Court Reduces Deductions for Purported Rent Payments to S Corp's Owners.
    • IRS Issues Proposed Regulations on Broker Reporting of Digital Asset Transactions.
    • Taxpayer Had to Include COD Income in Year Lender's Time to File a Claim Expired.
    • Ninth Circuit Upholds $8 Million Penalty Against Promoter of Timeshare Donation Scheme.
    • IRS Delays Effective Date of SECURE 2.0 Act Roth Catchup Provision Two Years.
    • IRS Issues Proposed Regs on Prevailing Wage and Apprenticeship Requirements for Increased Clean ...
    • Loans Discharged by Cancellation of Life Insurance Result in Taxable Distributions.
    • Late-Filed Return Nixes Taxpayer's Claim for Refund of Excess Withholdings.
    • Trust's Filing of Form 843 Did Not Qualify as a Valid Informal Refund Claim.
    • Insolvent S Corp Can't Exclude Income from Debt Cancelled as Part of Sale of Property.
    • Seventh Circuit Blocks Basketball Team Seller's Deduction for Deferred Comp Liability.
    • IRS Provides Guidance on Electronic Filing Exemptions, Waivers, and Rejections.
    • IRS Rules That Receipt of Crypto Units As Rewards for Staking Is Taxable Income.
    • IRS Issues Final Regs Allowing Assessments of Erroneous Refunds of COVID-19 Credits.
    • IRS Provides Guidance on Requirements for Claiming Home Energy Audit Credit.
    • Employers Can't Rely on Supply Chain Disruptions to Claim Employee Retention Credit.
    • Reporting Workers' Comp on W-2 May Result in Liability Under Section 7434.
    • Tax Court Rejects Charitable Deduction for Purported Bargain Sale of Land.
    • Proposed Regs Clarify Taxability of Insurance Not Paid for Actual Medical Expenses.
    • Third Circuit Affirms That Uncashed Checks Had to be Included in Gross Estate.
    • IRS Provides 2023 Transition Relief for Required Minimum Distributions.
    • Fifth Circuit: Filing of False Payment Plan Statement Is Sufficient Evidence of Tax Evasion.
    • Taxpayers Improperly Calculated Mortgage Interest Deduction for Year Home Was Sold.
    • Passthrough Losses Disallowed Due to Taxpayers' Lack of Outside Basis in Partnerships.
    • Taxpayer Properly Excluded Cancelled Debt from Income Due to Insolvency.
    • No FICA Tax Refund for Non-U.S. Worker Who Failed to Obtain Official Certificate.
    • IRS Announces That COVID-19 Rules for High Deductible Health Plans Expire After 2024.
    • Taxpayer Had Reasonable Cause for Incomplete Substantiation of Conservation Easement.
    • Taxpayer Can't Avoid IRS Levy by Transferring Cello to a Trust.
    • Tax Court Rejects Petition Electronically Filed 11 Seconds After Midnight.
    • Chief Counsel's Office: Wellness Indemnity Payments Are Taxable Income and Wages.
    • Eight Circuit: Value of Taxable Estate Includes Insurance Proceeds Used to Redeem Shares.
    • IRS Issues Guidance on Elective Payments and Transfers of Energy Credits.
    • Tax Court Denies Litigation Costs to Taxpayer; IRS's Position Was Substantially Justified.
    • District Court Rules IRS's John Doe Summons on Coinbase Was Not Unconstitutional.
    • Tax Court: Discovery in Whistleblower Cases Requires Showing of Bad Faith by IRS.
    • Fourth Circuit Rejects Presumption of Delivery Under Common Law Mailbox Rule.
    • Eleventh Circuit: Hobby Losses Are Deductible Only as Miscellaneous Itemized Deductions.
    • Fourth Circuit Affirms Tax Court's Holding That CEO's Bonuses Were Excessive.
    • Estate Tax Liability Applies to Persons Who Received Property After Decedent's Death.
    • Tax Court Lacks Jurisdiction Over Seriously Delinquent Tax Debt Notice Requirement.
    • Supreme Court Resolves Circuit Split on Notice Requirement for Third Party Summonses.
    • Tax Court: Fuel Blender's Excise Tax Credits Must Be Factored Into COGS Determination.
    • Assessment Was Untimely Because Taxpayer's Disclosures Triggered Statute of Limitations.
    • IRS Can Offset COVID-19 Tax Credits Against Liabilities of Third-Party Payors.
    • Biotech Company Overstated Expenses in Calculating Research Credit.
    • IRS Provides Initial Guidance on Domestic Content Bonus Credit.
    • Court Rebuffs IRS's Request to Summarily Decide Semi Truck Excise Tax Case.
    • Statute of Limitations on Assessment Does Not Apply to Tax Shelter Promoter Penalty.
    • No Deduction Allowed in 2012 for Lawsuit Settlement Check Delivered in 2013.
    • Interest Received on Past-Due Child Support Was Taxable Income.
    • Taxpayer Prevails in Dispute Involving Receipt of Partnership Units for Services.
    • Tax Court Dismisses Petition Filed Electronically Five Minutes Past Midnight.
    • Chief Counsel's Office Explains Substantiation Requirements for Cafeteria Plan Payments.
    • Election to Apply Tax Refund to Next Year's Taxes Did Not Bar Bankruptcy Discharge.
    • Tax Court Holds That Virgin Islands Tax Return Did Not Trigger Statute of Limitations.
    • Eleventh Circuit: Tax Court Has No Jurisdiction to Redetermine Interest on Deposit.
    • IRS Obsoletes Decades-Old Guidance on Accounting for Research and Experimental Costs.
    • Protocol Upgrade to Blockchain Distributed Ledger Does Not Result in Gain or Loss.
    • Taxpayers' Attempt to Exclude Income and Defer Gain Using CRATs Falls Short.
    • Court Holds That IRS Waited Too Long to Recover Excess Interest via Refund Offset.
    • IRS Cannot Assess Penalties for Failing to Report Interests in Foreign Corporations.
    • Proposed Regulations Identify Micro-captive Transactions As Listed Transactions.
    • Disability Benefits Paid Under Dual-Purpose Statute Were Excludable from Income.
    • Penalty for Frivolous Filings Applies to Returns Made on Behalf of Other Taxpayers.
    • IRS Provides Safe Harbor Language for Conservation Easement Deeds.
    • IRS Issues Proposed Regulations on Supervisory Approval Of Penalty Assessments.
    • No Stepped-Up Basis for Trust Assets That Were Not Included in Gross Estate.
    • EV Credit Proposed Regs Implement Vehicle Component Requirements; Include Special Rules for ...
    • Tax Liens Allowed Chapter 7 Trustee to Avoid Disclaimed Inheritance Under Federal Law.
    • Trust Language Doomed Estate's Deduction for Transfer of CRAT Interest to Charity.
    • IRS FAQs Address Medical Expenses Related to Nutrition, Wellness, and General Health.
    • Change in Treatment of Leased Farmland Was an Improper Accounting Method Change.
    • Court Orders IRS to Refund Excessive Tax Return Preparer Fees.
    • Lawyer's Claimed Deduction for Racing Car Activities Stalls Out in Tax Court.
    • Tax Court Holds That Blog Posts Were Properly Admitted in Innocent Spouse Case.
    • Plan to Avoid Gain on Sale of Company by Donating Shares to Charity Goes Awry.
    • IRS Provides Guidance on Treatment of Nonfungible Tokens as Collectibles.
    • Proposed Regulations Implement the Advanced Manufacturing Investment Credit.
    • Taxpayer Survives Summary Judgment in Conservation Easement Case.
    • Third Circuit Finds Horse Farm with History of Losses Wasn't Operated for Profit.
    • Extension Requests and Other Filings Didn't Constitute an Informal Refund Claim.
    • Chief Counsel's Office: Conservation Easement Promoter's Gain is Ordinary Income.
    • Ninth Circuit: Partnership Did Not File Return by Faxing It to IRS Agent.
    • No Whistleblower Award for Information Leading to the Creation of OVDI Program.
    • IRS Issues Final Regs on Electronic Filing; Lower Thresholds Don't Apply Until 2024.
    • Value of QTIP Trust in Estate Wasn't Reduced by Payment for Undistributed Income.
    • IRS Lengthens Refund Lookback Period for Returns with Covid-Postponed Due Dates.
    • Supreme Court Reins in FBAR Penalties; Rejects IRS's Per-Account Approach.
    • Fourth Circuit Reverses Lower Courts; ACA Penalty Is Entitled to Priority Status in Bankruptcy.
    • IRS Proposes New Voluntary Tip Reporting Program for Service Industry Employers.
    • Divided Tax Court: IRS's Section 482 Income Allocation is Valid; Foreign Legal Restriction ...
    • What to Do About Missing or Incorrect Forms W-2 and Forms 1099.
    • Nonresident Alien May Have Ordinary Income on Sale of Interest in U.S. Partnership.
    • IRS Revises Vehicle Classifications for Purposes of Sec. 30D Clean Vehicle Credit.
    • IRS Advises That 2022 State Relief Payments Should Not Be Reported as Income.
    • Tenth Circuit Agrees Reverses Tax Court; Upholds Civil Fraud Penalty.
    • IRS Issues Annual Vehicle Depreciation and Lease Inclusion Amounts for 2023.
    • Ninth Circuit Affirms Tax Court's Ruling That It Can't Refund a TIPRA Payment.
    • Tax Court Upholds IRS Certification of Taxpayer's Seriously Delinquent Tax Debt.
    • Engineering Firm Entitled to Section 179D Deduction Allocated from Federal Facility.
    • New Procedure Allows Real Estate Developers to Use Optional Safe Harbor Method.
    • Cryptocurrency Deduction Cannot be Valued Using a Cryptocurrency Exchange.
    • IRS Properly Issued Summonses Relating to Monetized Installment Sale Transactions.
    • Tax Court Holds That Despite Losses, Cattle Ranch Was Operated for Profit.
    • Defense Contractor Can't Exclude Employer-Provided Housing from Income.
    • January 31 Deadline Draws Near for Forms W-2, 1099-MISC, and 1099-NEC.
    • CPA Sample Client Letter: Requirement to File Forms 1099-MISC, and 1099-NEC. January 2023.
    • Chief Counsel's Office Says No Section 165 Deduction for Decline in Value of Cryptocurrency.
    • New Mexico Law Doesn't Allow Debtor to Exempt EITC Refunds from Bankruptcy Estate.
    • IRS Delays Implementation of Lower $600 Form 1099-K Reporting Threshold to 2023.
    • IRS Issues Standard Mileage Rates for 2023; Business Use Increases 3 Cents Per Mile.
    • IRS Eliminates Audit Protection for Certain Sec. 174 Accounting Method Changes.
    • IRS Provides Guidance Regarding Clean Vehicle and Commercial Clean Vehicle Credits.
    • 2023 Consolidated Appropriations Act Signed into Law; Overhauls Retirement Plan Tax Rules.
    • Debtors Cannot Hide Funds by Parking Them With the IRS as Estimated Tax Payments.
    • Proposed Regs Identify Syndicated Conservation Easements as Listed Transactions.
    • Final Regs Permanently Extend Deadline for Furnishing Forms 1095-B and 1095-C.
    • IRS Gives Automatic Approval for Accounting Method Changes for Research Expenses.
    • IRS Finalizes Rules on Treatment of Partnership Special Enforcement Matters.
    • Top Tax Developments of 2022.
    • Year-End Spending Bill Includes Retirement Plan, Conservation Easement Changes.
    • Taxes Shown on Belated Tax Filings Don't Qualify for Discharge in Bankruptcy.
    • Ninth Circuit Reverses District Court; Trustee Can't Avoid Tax Lien on Homestead.
    • Tax Court Holds That 90-Day Deadline is Jurisdictional, Not Subject to Equitable Tolling.
    • On Remand from Eighth Circuit, Mayo Clinic Wins $11 Million UBIT Refund.
    • Section 2032A Election on Estate Return Filed Five Years Late Is Valid.
    • IRS Issues Guidance on Prevailing Wage and Apprenticeship Requirements.
    • Ninth Circuit Rejects En Banc Rehearing of Mandatory Repatriation Tax Case.
    • Section 7434 Only Creates a Cause of Action if Information Return is False or Misleading.
    • Trusts Can't Recover Underpayment Interest on $71 Million Deposit Not Used to Pay Tax.
    • Tax Court Invalidates Notice Identifying Conservation Easements as Listed Transactions.
    • Tax Court Rejects Deduction for Poorly Documented NOLs from Restaurant Franchises.
    • IRS Provides Procedure for Certain Large Businesses to File Qualified Amended Returns.
    • Ninth Circuit's Opinion in Seaview Trading Vacated; En Banc Rehearing Ordered.
    • Company Owner's Daughter Is a Responsible Person for Two Payroll Quarters.
    • Ninth Circuit Vacates Tax Court Decision That Denied Litigation Costs to Taxpayer.
    • 2023 Contribution Limit for 401(k) Plans Increases to $22,500; IRA Limit Is $6,500.
    • 2022 Year-End Tax Planning for Businesses. Client Letter Included.
    • CPA Sample Client Letter: 2022 Year-End Tax Planning for Businesses.
    • 2022 Year-End Tax Planning for Individuals. Client Letter Included.
    • CPA Sample Client Letter: 2022 Year-End Tax Planning for Individuals.
    • Confirmation of Bankruptcy Plan Doesn't Lift Automatic Stay of Tax Court Proceedings.
    • Accounting Firm Distributed Client-Based Intangibles to Former Partners.
    • IRS Expands Cafeteria Plan Change-in-Status Rules in Connection with Family Glitch Fix.
    • IRS Announces 2023 Inflation Adjustments; Social Security Benefits Up 8.7% for 2023.
    • IRS Finalizes Regs That Fix "Family Glitch" in Premium Tax Credit.
    • Daughter Wasn't Authorized to Represent Deceased Mother in Tax Court.
    • Architecture Firm Can Continue with Refund Suit Against the IRS.
    • Chief Counsel's Office Advises on Application of Codified Economic Substance Doctrine.
    • Transfers of Crops to CRATs Are Not Deductible as Charitable Contributions.
    • IRS Addresses Confusion over Changes to RMD Rules; Postpones Certain Deadlines.
    • Sole Shareholder Received Constructive Distributions from Fraudulent Transactions.
    • Annual Per-Diem Guidance Issued for 2022-2023.
    • Taxpayer Using Swiss Accounts to Hide Income from His Wife and IRS Subject to Civil Fraud Penalty.
    • Donor Does Not Have a "Right" to Decide Where Donor Advised Funds Are Donated.
    • Proposed Regs Address Resolution of Federal Tax Controversies without Litigation.
    • Improperly Forgiven PPP Loans Can't Be Excluded from Income.
    • Court Rejects IRS Motion for Summary Judgment in Conservation Easement Case.
    • Harvard Professor's Conviction for Filing False Tax Returns and FBAR Violations Upheld.
    • Settlement Includable in Income; Agreement Failed to Specify if Personal Injuries Were Physical.
    • Couple Can't Avoid Accuracy-Related Penalties Based on Filing of Amended Returns.
    • Student Debt Relief Plan Could Result in State Income Tax Liability in Some States.
    • Fifth Circuit Reverses District Court in Refund Action involving TEFRA Partnerships.
    • Eleventh Circuit Affirms Tax Court's Disallowance of $78 Million Tax Shelter Loss.
    • Tax Court Rejects Taxpayer's Challenges to Validity of Closing Agreement.
    • Third Circuit Affirms That Executor Can Be Held Liable for Estate Tax Deficiency.
    • Court Nixes IRS Attempt to Change Loan Payment into Sec. 707(c) Guaranteed Payment.
    • IRS Provides Relief for Certain 2019 and 2020 Tax Return Penalties.
    • D.C. Circuit Allows Disclosure of Former President Trump's Tax Returns to Ways and Means Committee.
    • Tax Court Remands Whistleblower Case Without Retaining Jurisdiction.
    • Fifth Circuit Upholds $1.5 Billion Judgment Against Oil and Gas Company.
    • Veteran's Service-Related Pension Was Taxable, Despite a VA Disability Determination.
    • Pursuit of After-Tax Profit Through Use of Tax Credits Is a Legitimate Business Activity.
    • In-Depth Report: Key Tax Provisions of the Inflation Reduction Act. (Client Letters Included)
    • CPA Sample Client Letter: Inflation Reduction Act (Individuals).
    • CPA Sample Client Letter: Inflation Reduction Act (Businesses).
    • Refund of Withheld Social Security Income Was Exempt in Bankruptcy.
    • Weekend Vote-a-Rama Ends with Senate Passing Healthcare/Tax/Climate Bill.
    • Support Payments with Child-Related Contingencies Were Not Deductible as Alimony.
    • Third Circuit: Taxpayer's Actions Indicated His Failure to File FBAR Was Willful.
    • Key Parts of Build Back Better Act Revived as the 2022 Inflation Reduction Act.
    • Criminal Referral of LLC's Agent Didn't Preclude IRS from Issuing Summons to LLC.
    • IRS Can Disclose Return Information to Tax Court in Whistleblower Case.
    • Veteran's Refund Action for Tax Paid on Recouped Separation Pay Was Time-Barred.
    • Fingerprinting Delays of IRS Personnel May Increase Taxpayer Data Exposure, TIGTA Warns.
    • Trust Owner Was Unjustly Enriched by Distributions, Except for Portion Used to Pay Taxes.
    • Assignment-of-Income Doctrine Precludes Taxpayer's Charitable Deduction.
    • IRS Extends Time for Making a Portability Election From Two to Five Years.
    • Tax Lien Filed in County Where Taxpayer Didn't Live Was Not Effective.
    • U.S. Contractor Living in Saudi Arabia Qualified for Foreign Earned Income Exclusion.
    • IRS Lien Attached to Sale Proceeds Paid Directly to Taxpayer's Ex-Wife as Alimony.
    • Sixth Circuit Finds Millionaire Car Salesman Guilty of Tax Evasion.
    • Offer In Compromise Is Considered Rejected When Returned to Taxpayer.
    • Charity's Acknowledgment Letter Failed Substantiation Test; Deduction Denied.
    • Proposed Regs Address Deductions for Interest and Claims Against an Estate.
    • Former CEO Accused of Large-Scale Tax Evasion Found Competent to Stand Trial.
    • Tax Court Rejects Partnership's Attempt to Treat Land Sold at a Loss as Inventory.
    • Mortgage Interest Deduction Denied Due to Uncertain Foreclosure Proceeds Allocation.
    • IRS Increases Optional Mileage Rates for Last 6 Months of 2022 Due to Higher Fuel Prices.
    • Website Was a Trade or Business When Opened to the Public, Despite Earning No Income.
    • Third Circuit Affirms Penalty for Willfully Failing to Disclose Foreign Bank Accounts.
    • Chief Counsel's Office Advises That Termination Fees Are Capital Losses Under Code Section 1234A.
    • Court Allows Adversary Proceeding Against Former S Corp Shareholders To Go Forward.
    • Prison Time Increased for Lawyer/CPA Who Used Sophisticated Means to Conceal Crimes.
    • Tenth Circuit Refuses to Void Ruling on Taxpayer's Employment Tax Liability.
    • Missing Document Dooms Taxpayer's Charitable Donation Deduction.
    • Bankruptcy Court Doesn't Buy IRS's Excuses for Attempting to Collect Discharged Debts.
    • IRS Updates FAQs for New Schedules K-2 and K-3.
    • Third Circuit: ACA Shared Responsibility Payment Is a Priority Claim in Bankruptcy.
    • Tenth Circuit Upholds Tax Court; Deals Significant Blow to Microcaptives.
    • Sixth Circuit Addresses Right of First Refusal in Low-Income Housing Credit Dispute.
    • Self-Directed IRA Retains Qualified Status and Is Exempt from Bankruptcy Estate.
    • Inspector General Report: IRS Needs Service-Wide Strategy to Address Electronic Filing Challenges.
    • IRS Allows Tax-Favored Paid Leave Donation Programs for Ukraine Relief Through 2022.
    • Ninth Circuit Reverses Tax Court; FPAA Ran Afoul of Statute of Limitations.
    • GAO Reports 44 Percent Drop in Audit Rates; Biggest Decrease Applies to Wealthiest Taxpayers.
    • Excess Contribution to IRA Precludes Annuity from Being Exempt in Bankruptcy Estate.
    • Chief Counsel's Office Has Authority to Override CCISO Innocent Spouse Determinations.
    • CPA Liable for Taxes and Penalties for Defrauding Investors and Lenders.
    • U.S. Official Can't Deduct Losses from Sales of Properties Purchased Using Ill-Gotten Funds.
    • Eighth Circuit Affirms Tax Court; Payments to Shareholders Were Disguised Dividends.
    • Proposed Regs Address TCJA Increase to Basic Exclusion Amount for Estate and Gift Tax.
    • Failure to Spend 750 Hours on Rental Real Estate Activities Kills Deduction.
    • Tax Court Can Review IRS Voluntary Classification Settlement Program Determinations.
    • Airline Tickets Given to Adult Relatives Must Be Included in Couple's Income.
    • Reversing Lower Courts, Supreme Court Holds Puerto Rico Residents Ineligible for SSI.
    • Supreme Court: 30-Day Deadline for Tax Court Petitions in CDP Cases Isn't Jurisdictional.
    • Company Liable for Back Taxes and Penalties for Misclassifying Nurses as Contractors.
    • Corporate Officer Can't Avoid Employee Classification for Employment Tax Purposes.
    • No Monetary Relief Available for Taxpayer Who Received Bad Tax Advice from Employer.
    • Tax Court Questions Whether Sale of Residence Was Due to Wife's Health Problems.
    • Taxpayer Beats IRS in Controversy Involving Payments to Continuing Care Community.
    • Proposed Regs Would Amend Premium Tax Credit to Fix "Family Glitch" in Affordable Care Act.
    • Fees Charged by Securities Exchange Were Not Domestic Production Gross Receipts.
    • IRS Fact Sheet Discusses Crowdfunding Tax Treatment and Recordkeeping.
    • Informal Discussion of Penalties Didn't Trigger Supervisor Approval Requirement.
    • IRS Provides Penalty Relief for Estimated Tax Underpayments to Farmers and Fishermen.
    • U.S. Shareholder's Treatment of CFC Stock Must Match CFC's Apportionment Method.
    • Annual Vehicle Depreciation and Lease Inclusion Amounts Reflect Jump in Inflation.
    • Ninth Circuit Reverses Tax Court; Agrees with IRS's Position on Penalty Approval.
    • IRS Issues New Tax Basis Form for S Corporation Shareholders.
    • IRS's Claim for Employer Shared Responsibility Payment Has Priority In Bankruptcy.
    • Sixth Circuit Reverses Lower Court; IRS Violated Administrative Procedure Act in Issuing Notice ...
    • Company's Payments for Coding Class Tuition Were Not Deductible Business Expenses.
    • Summary Judgment Denied in $9 Million FBAR Penalty Case.
    • Tax Court Reduces IRS Cuts to Compensation Deduction for CEO.
    • Taxpayer's Offer Letter to IRS Doomed Later Attempt to Recover Litigation Costs.
    • Circuits Split on Validity of Conservation Easement "Proceeds" Regulation.
    • Litigator Who Specialized in Tax Fraud Cases Is Liable for Tax Fraud Penalty.
    • Taxpayer Could Not Recover Litigation Costs Where IRS Promptly Conceded the Case.
    • Proceeds from Sale of Basketball Team Are Not Reduced by Unpaid Deferred Comp.
    • Traveling Steamfitter Properly Deducted Expenses While Away from Home.
    • Noncustodial Parent Qualified for Dependency Exemption Based on State Court Order.
    • IRS Won't Follow Court Ruling on Limitations Period for Backup-Withholding Assessments.
    • IRS Loses Big on Split-Dollar Life Insurance Estate Tax Case.
    • IRS Issues Proposed Regs on Required Minimum Distributions from Retirement Plans.
    • Conviction of Manufacturing VP for Failing to Remit Payroll Taxes Upheld.
    • Tax Court Can't Consider Refund Claim When IRS Collection Action No Longer Exists.
    • Supreme Court's Boyle Decision Applies to E-Filed Returns.
    • Constructive Distribution to Foreign Sub Results in Gain Recognition Under Sec. 367.
    • IRS Makes Significant Revisions to Automatic Accounting Method Change Procedure.
    • Updated IRS FAQs Explain How to Claim 2021 Recovery Rebate Credits.
    • State Law Gives IRS Priority Over Inheritors' Interest in Wrongful Levy Case.
    • Former IRS Attorney Loses Appeal in Tax Evasion Case.
    • Eleventh Circuit Remands Case to Recalculate Taxpayer's FBAR Penalties.
    • IRS Revises Guidance on Determining Substantially Equal Periodic Payments.
    • Property Leasing Website Is a Brokerage Service for Purposes of Sec. 1202.
    • IRS Provides Procedures for 2021 Non-filers to Access Tax Benefits.
    • Taxpayers Made Valid Informal Refund Claim, Despite Using Wrong Form.
    • D.C. Circuit Reverses Two Tax Court Rulings on Jurisdiction in Whistleblower Cases.
    • ER Doc Cannot Deduct Condo Costs as Office Expense.
    • Lower Reporting Thresholds Apply to Third Party Network Payments Beginning in 2022.
    • How to Handle Missing Forms W-2 and Forms 1099.
    • Unsigned Refund Claims Were Not "Duly Filed" and Thus Were Invalid.
    • Wealthy Doctor Who Lied and Hid Assets Can't Get Tax Debts Discharged.
    • Court Agrees with $8.46 Million Penalty on Promoter of Time-Share Donation Scheme.
    • Losses Incurred in Couple's Miniature Donkey Breeding Activity Are Deductible.
    • Court Stays Ruling Allowing Disclosure of Trump's Tax Returns Pending Appeal.
    • Eleventh Circuit Invalidates Extinguishment Proceeds Regulation.
    • Providing Substantial Services Turns Rental Income into Self-Employment Income.
    • January 31 Deadline Is Fast Approaching for Forms W-2 and 1099.
    • CPA Sample Client Letter: Requirement to File Forms 1099. January 2022.
    • Debtor Cannot Proceed Under Bankruptcy Subchapter V.
    • Pending Refund Action Barred Tax Court from Hearing Innocent Spouse Claim.
    • Business, Medical, and Moving Standard Mileage Rates Increase for 2022.
    • Tax Court Rejects Taxpayer's Claim for Relief Under Section 66(c) on S Corp Income.
    • Failure to Stick to Business Plan Dooms Taxpayer's Business Expense Deductions.
    • IRS Issues Automatic Change Procedures to Comply with Small Business Accounting Regs.
    • Top 12 Tax Developments of 2021.
    • Proposed Regs Permanently Extend Form 1095 Deadline, Eliminate Transitional Relief.
    • Employer's Inclusion of Reimbursed Expenses on Form 1099 Was Not Fraudulent.
    • Fifth Circuit Weighs In on FBAR Penalty Issue; Finds Taxpayer Liable for Higher Penalty.
    • IRS Provides Guidance on Retroactive Termination of Employee Retention Credit.
    • Court Denies Estate's Deduction for Charitable Contribution of Farm Sale Proceeds.
    • 100-Percent Meal Deduction Applies to 2021 and 2022 Per Diem Rate or Allowance.
    • IRS Issues Inflation-Adjusted Amounts for 2022.
    • Physical Possession of Coins Owned by Self-Directed IRA Was a Taxable Distribution.
    • IRS Explains Treatment of Tax Items Affected by Paycheck Protection Program Loans.
    • Build Back Better Bill Passes by Slim Margin in House; Faces Hurdle in Senate.
    • Tax Court's Jurisdiction Over Whistleblower Appeals Survives Whistleblower's Death.
    • CPA's Advice Did Not Provide Reasonable Cause for Late Returns and Tax Payments.
    • Supervisory Approval Issue Must be Raised during Partnership-Level Proceedings.
    • IRS Releases Retirement-Related COLAs; 401(k) Contribution Limit Increases to $20,500.
    • 2021 Year-End Tax Planning for Businesses. Client Letter Included.
    • CPA Sample Client Letter: 2021 Year-End Tax Planning for Businesses.
    • House Sends $1T Infrastructure Package to Biden; Build Back Better Bill on Hold.
    • CPA Sample Client Letter: Infrastructure Investment and Jobs Act - General Explanation.
    • Debtor Must Pay Over Tax Refund Under Almost-Complete Bankruptcy Plan.
    • Social Security Administration Announces a 5.9 Percent COLA.
    • Business Owner's Tax Background Supported Imposition of Fraud Penalty.
    • Claim of Right Doctrine Doesn't Apply to Trustee's Voluntary Repurchase of Stock.
    • 2021 Year-End Tax Planning Guide (Individuals). Client Letter Included.
    • CPA Sample Client Letter: 2021 Year-End Tax Planning for Individuals.
    • IRS Provides Standards for LLCs to be Recognized as Tax Exempt Under Sec. 501(c)(3).
    • Court Denies Refund Claim Because Taxpayer Missed Deadline for Changing Filing Status.
    • IRS Can't Assess Underpayment Interest Where Overpayment Credits Exceed Deficiency.
    • Court Rejects Government Attempt to Value Gifts Using Estate Tax Rules.
    • Tax Court Allows Alimony Deduction for Health Insurance Purchased with Pre-Tax Earnings.
    • Second Circuit Shoots Down States' Constitutional Challenges to SALT Deduction Cap.
    • Taxpayer Avoids Penalty for Deducting Litigation Fees Involving Ex-Wife.
    • Court Enjoins Enforcement of IRS Reporting Rules for Micro-captive Transactions.
    • IRS Extends Replacement Period under Section 1033 for Certain Livestock Sales.
    • Value of Taxable Estate Includes Insurance Proceeds Used to Redeem Shares.
    • CPA's Notation About Client's Foreign Earnings Is Admissible in Client's Trial.
    • IRS Issues Regs on Recapturing Excess COVID Employment Tax Credits in 2021.
    • Close Vote Expected on Bipartisan Infrastructure Bill.
    • Eleventh Circuit Upholds Conviction for Elaborate Scheme to Avoid Paying Taxes.
    • Knowledge of Husband's Tax Scheme Dooms Wife's Innocent Spouse Relief Claim.
    • IRS Issues 2021-2022 Special Per Diem Rates.
    • Tax Court Holds That Retiree's Acting Career Was a Trade or Business.
    • Levy Release for Economic Hardship Doesn't Apply to Corporations.
    • SBA Implements Major Changes to COVID Economic Injury Disaster Loan Program.
    • IRS Issues 2021 Reporting Guidance for Covid-Related Qualified Leave Wages.
    • Deduction for Costs Incurred in Searching for New Business Opportunities Disallowed.
    • Whistleblower Award Properly Denied Where Info Didn't Lead to IRS Examination.
    • IRS Error Gives Taxpayer Day in Court on Claim for Innocent Spouse Relief.
    • Defense Contractor Entitled to Foreign Earned Income Exclusion.
    • Seventh Circuit Reverses $9 Million Excise Tax Judgment Against Trucking Company.
    • IRS Defers Applicability Date of Publicly Traded Partnership Withholding Regs.
    • Chief Counsel Addresses Late Payments of Taxes Deferred Under CARES Act.
    • IRS Provides Luxury Auto Depreciation Limits and Lease Inclusion Amounts for 2021.
    • Tax Court's Ruling That Author Underpaid Self-Employment Taxes Affirmed on Appeal.
    • Missing Estate Tax Info Might Provide Reasonable Cause for Late Return.
    • IRS Issues Accounting Method Change Procedure to Comply With Final Sec. 451 Regs.
    • Tax Treaty Doesn't Allow Foreign Tax Credit to Offset Net Investment Income Tax.
    • Gross Receipts Safe Harbor Will Help Employers Qualify for Employee Retention Credit.
    • Employee Retention Credit Does Not Apply to Wages of Owner and Family.
    • Tenth Circuit Rejects Constitutional Challenge to Passport Revocation for Tax Debts.
    • Partnership Fails in Attempt to Deduct Loss With Related Party.
    • IRS Provides Additional Guidance on Temporary COBRA Premium Assistance.
    • Premature Estate Distributions May Result in Executor Being Liable for Estate's Taxes.
    • Whistleblower Office Intentionally Deceived Whistleblower and Didn't Follow Regs.
    • Proposed Regulations Implement New Rules for Electronic Return Filing.
    • SBA Substantially Improves PPP Loan Forgiveness Process for Loans of $150,000 or Less.
    • Fifth Circuit Asks State Court to Decide Property Interest in Wrongful Levy Case.
    • Taxpayer's Claim for Refund Survives Government's Motion to Dismiss for Lack of Specificity.
    • Incarceration and Embezzlement Weren't Reasonable Cause for Late Filed Tax Returns.
    • Taxpayer Awarded Costs After Court Finds IRS's Positions on Basis and Method of Accounting ...
    • Pastor Who Failed to File Form 4361 Was Not Exempt from Self-Employment Tax.
    • Married Taxpayers Who Received Separate Notices May File Joint Tax Court Petition.
    • Eleventh Circuit Affirms Tax Court's Denial of Deduction for Conservation Easement.
    • Eighth Circuit: Ex Parte IRS Communications Didn't Warrant New CDP Hearing.
    • Chief Counsel's Office: Abusive Tax Shelter Penalties Aren't Limited to Initial Promotion.
    • Tax Court Addresses Basis Reduction Rules When Investment Property Debt Is Discharged.
    • IRS Provides 2021 Penalty Relief for New Schedules K-2 and K-3.
    • Supreme Court Reverses Ninth Circuit; Rejects California's Donor Disclosure Law.
    • IRS Provides Special Election Procedures for Taxpayers with Farming Loss NOLs.
    • Eleventh Circuit Affirms 90-Month Prison Sentence for Former Tax Return Preparer.
    • Final Regs on Postponement of Disaster Deadlines Address Sec. 7508A(d) Ambiguities.
    • Taxpayers Can't Deduct Business Expenses While Still in Startup Phase.
    • Court Finds CPA Should Have Known Better Regarding FBAR Reporting Obligations.
    • Supreme Court Again Upholds Constitutionality of Affordable Care Act.
    • IRS Explains How to Change Depreciation Method to Comply with Recent Law Change.
    • IRS Guidance Allows Partnerships to Apply 30-Year Recovery Period to Rental Property.
    • Fifth Circuit Affirms Tax Court's Ruling That MoneyGram Is Not a Bank.
    • Manufacturer's Minimum Rebate Guarantee Is Not Deductible in Year Made.
    • S Corporation Owner Not Entitled to Theft Loss Deduction for Embezzlement Loss.
    • Tax Court Upholds Validity of Marriage for Purposes of Estate Tax Marital Deduction.
    • Tax Court Erred by Invoking Substance-Over-Form to Reverse Congressional Judgment.
    • Chief Counsel Addresses Overpayment Interest Start Date When Filing Status Changes.
    • White House Releases Tax Proposals as Part of Fiscal Year 2022 Budget Plan.
    • Eighth Circuit Partially Upholds Regulation Defining Educational Organizations.
    • Taxpayer With No Gross Receipts Can't Recover Cost of Goods Sold.
    • Purchase of U.S. Residential Property from a Foreign Entity Causes Withholding Tax Headaches for ...
    • Supreme Court Allows Challenge to Micro-Captive Insurance Transaction Reporting Requirements to ...
    • New Procedures Allow Taxpayers Who Don't File 2020 Returns to Access Tax Benefits.
    • IRS Guidance Provides Details on Temporary COBRA Premium Assistance.
    • IRS Issues 2022 Inflation Adjusted Amounts for Health-Related Arrangements.
    • Estate of Michael Jackson Wins Favorable Ruling in Valuation Dispute with IRS.
    • Eleventh Circuit Upholds Denial of Entertainment Company Founder's $19 Million NOL Deduction.
    • Taxpayers' Bad Investment Didn't Give Rise to Theft Loss Deduction.
    • Circuits Split on Jurisdiction Over Claims for Overpayment Interest.
    • Net Investment Income Tax Applies to Dividends Received by Majority Shareholder.
    • IRS Addresses Dependent Care Benefits Under Extended Claims or Carryover Period.
    • Court Upholds Third-Party Summons on Cannabis Dispensary's Software Vendor.
    • Judge's Lavish Spending Precluded Discharge of Taxes in Bankruptcy.
    • Court Upholds $3 Million Penalty for Willful Failure to Report Foreign Bank Account.
    • CPA's Signature on Client's Refund Claim Doesn't Pass Muster; No Refund Allowed.
    • Ninth Circuit Upholds Denial of Cannabis Dispensary's Claimed Exclusions.
    • IRS Won't Follow Tax Court's Ruling in Insolvency Exception Case.
    • Drug Manufacturer Must Capitalize Certain Legal Expenses Incurred in Obtaining Patents.
    • Certain 2020 PPP-Related Expenses Are Deductible in 2021; Amended Returns Not Required.
    • Substantial Discretionary Spending Didn't Preclude Discharge of Taxes in Bankruptcy.
    • Taxpayer Can't Recoup Damages for Coin Collection Seized During Search of Her Home.
    • Tax Court Rejects Constitutional Challenge to IRS Certification of Delinquent Tax Debts.
    • Clothing Company's Design Process Doesn't Qualify for Research Credits.
    • IRS Suspends Repayment of Excess Advance Payments of the 2020 Premium Tax Credit.
    • Tax Court Holds That Split-Dollar Insurance Benefits Are Guaranteed Payments.
    • IRS Provides Guidance on Temporary 100-Percent Deduction for Business Meal Expenses.
    • IRS Clarifies Rules for 2021 Employee Retention Tax Credit.
    • Second Circuit Upholds Lump Sum Garnishment Order as Restitution for Tax Crimes.
    • D.C. Circuit Affirms Tax Court's Ruling That Investment Partnership Was a Sham.
    • Court Upholds Constitutionality of Passport Revocations for Delinquent Tax Debts.
    • TCJA Change to Gambling Loss Limit Applies Only to Individuals.
    • Amounts Paid for Certain Personal Protective Equipment Treated as Medical Expenses.
    • Ninth Circuit: Late FBAR Penalty Applies Per Filing, Not Per Account.
    • SBA Updates PPP Guidance for Changes Made by Recent Legislation.
    • IRS Postpones Multiple Tax Filing and Payment Deadlines.
    • Taxpayers' Closing Agreement on FBAR Penalties Wasn't Entered Under Duress.
    • Payments to Microcaptive Insurance Company by Family Business Aren't Deductible.
    • Faxing a Courtesy Copy of Taxpayer's Return to IRS Doesn't Qualify as a "Filing".
    • Business Owner's Reliance on Competent Bookkeepers Helps Avoid Penalties.
    • Court Holds Certain Purchases Using Credit Card Rewards Are Taxable.
    • SBA Loosens Rules on PPP Loan Amount Calculations and Eligibility Requirements.
    • IRS Provides Updated FAQs and Examples on Employee Retention Credit.
    • Congress Passes $1.9 Trillion Covid Relief Package Loaded with Tax Provisions.
    • CPA Sample Client Letter: American Rescue Plan Act.
    • Court Values Estate's LLC Interests; Discounts Apply to Split Donation.
    • Eighth Circuit Reverses Tax Court; Virgin Islands Tax Return Did Not Trigger Statute of Limitations.
    • Bankruptcy Court Allows Debtors to Retain Their Tax Refund for Necessary Expenses.
    • Medical Cannabis Dispensary's Claimed Deductions Go Up In Smoke In Tax Court.
    • Tax Court Allows Taxpayer to Disregard Form of Transaction Under Step Transaction Doctrine.
    • IRS Provides Additional COVID-19 Relief Guidance for Cafeteria Plans.
    • Tax Court Upholds Denial of $5.4 Million Deduction for Conservation Easement.
    • First Circuit Upholds Garnishment Order on Convicted CFO's Retirement Account.
    • Additional Tax on Early IRA Withdrawals Doesn't Require IRS Supervisory Approval.
    • Farming Activity Was Not a Trade or Business; Expenses Must be Capitalized as Start-Up Costs.
    • Tax Court Denies Attorney's Deductions for Lodging and Travel Expenses.
    • IRS Provides Safe Harbor for Eligible Educators to Deduct Unreimbursed PPE Expenses.
    • SBA Issues Interim Final Rule on New Changes to Paycheck Protection Program.
    • IRS Not Required to Separately Assess Transferees for Transferor Liability.
    • Exxon Mobil Avoids $200 Million Penalty for Erroneous Refund Claim.
    • Payments to Shareholders Were Disguised Dividends, Not Deductible Management Fees.
    • Notice Mailed to Address Shared with Other Businesses Started 30-day Filing Deadline.
    • IRS Addresses Calculation of Specified Cooperatives' W-2 Wages Under Sec. 199A.
    • IRS Provides Penalty Relief to Partnerships for Form 1065 Reporting Inaccuracies.
    • IRS Finalizes Regs on TCJA Disallowance of Deduction for Fines and Penalties.
    • SBA Issues Guidance on Re-Opened Paycheck Protection Program.
    • Fourth Circuit Affirms Denial of Charitable Deduction for "Donation" of Home.
    • Reversing Tax Court, Third Circuit Holds That IRS Did Not Send Notice to Taxpayer's Last Known ...
    • IRS Grants Temporary Relief for Employers Using Automobile Lease Valuation Rule.
    • IRS Issues Final Regs on Sec. 163(j) Interest Expense Deduction Limitation.
    • IRS Obsoletes Previous Guidance on Deductibility of PPP Loan Expenses.
    • Parkers Tax Library - Professional Federal Tax Research - Most Popular Tax Articles
    • Tax Research - Tax Analysis Articles Archived 2020-2018 - Parker Tax Publishing
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    • Top 10 Tax Developments of 2020.
    • February 1 Deadline Looms for Forms W-2 and 1099-MISC, and New Form 1099-NEC.
    • CPA Sample Client Letter: Requirement to File Forms 1099.
    • Taxpayer Serving as "Voice of Organization" Is Liable for Penalties as Nonprofit's Alter Ego.
    • Business, Medical, and Moving Standard Mileage Rates Decrease for 2021.
    • Approaching Deadlines for Forms W-2 and 1099s; What to Do About Missing Forms.
    • Final Sec. 451 Regs Introduce New Methods for Income Inclusion and Cost Offsets.
    • IRS Finalizes Simplified Tax Accounting Regulations for Small Businesses.
    • President Signs $900 Billion Covid Relief Package; Paycheck Protection Program Expanded.
    • Third Circuit Upholds Attorney's Conviction for Failing to Collect and Pay Payroll Taxes.
    • Taxpayer's Conduct in Violating FBAR Rules Was Reckless; Higher Penalties Apply.
    • IRS Finalizes Regulations on Extended Rollover Period for a Qualified Plan Loan Offset.
    • Partnership Tax Insurance Premiums Are Nondeductible.
    • Corporation Was Required to Report Notes Received on Sale of Products as Income.
    • Statute of Limitations Bars Backup-Withholding Assessment Despite Business Owner's Failure to ...
    • IRS Finalizes Transportation and Commuting Expense Regs.
    • IRS Adopts Rules for Exempt Organizations with More Than One Unrelated Business.
    • Coca-Cola's Challenge to IRS Transfer Pricing Adjustments Fizzles Out in Tax Court.
    • Proposed Regs Cover Wide Array of Partnership Special Enforcement Matters.
    • Final Section 1031 Regs Eliminate "Purpose or Use Test" from Real Property Definition.
    • IRS Confirms Deductibility Rules for Expenses Paid with PPP Funds; Issues Safe Harbor.
    • Doctor Is Subject to Penalties for Failing to Report Employer Welfare Benefit Payments.
    • Ninth Circuit Upholds Tax Court's Adjustments Cement Company's Depletion Deduction.
    • Professional Employer Organization Defeats IRS Appeal in FICA Tip Credit Case.
    • IRS Allows Taxpayers to Choose to Apply Final or Proposed Bonus Depreciation Regs.
    • IRS Announces Approval of SALT Cap Workarounds Using Passthrough Entities.
    • 2020 Year-End Tax Planning for Individuals.
    • CPA Sample Client Letter: 2020 Year-End Tax Planning for Individuals.
    • Beneficiary Is Liable for Estate Taxes as a Result of Transfers Received.
    • Eleventh Circuit Reverses Decision Disallowing Conservation Easement Deductions.
    • Tax Prep Software Troubles and Incompetent Employees Don't Negate Penalties.
    • Tax Court: Gambling Losses Were Substantiated Using Statistical Analysis.
    • IRS Releases Retirement-Related COLAs; 401(k) and IRA Contribution Limits Unchanged.
    • IRS Issues Inflation-Adjusted Amounts for 2021.
    • 2020 Year-End Tax Planning for Businesses.
    • CPA Sample Client Letter: 2020 Year-End Tax Planning for BUSINESS.
    • Employer Must Withhold and Report Plan Payments to Unclaimed Property Funds.
    • Daily Fantasy Sports Fees Are Amounts Paid for Wagering Transactions.
    • IRS Updates List of Permissible Reasons for 60-day Rollover Waiver; Includes Distributions to a ...
    • IRS Relaxes Withholding Rules on Transfers of Partnership Interests.
    • Tax Court: IRS Can't Assess 40% Penalty After Failing to Get Approval for 20% Penalty.
    • Simplified PPP Loan Forgiveness Form Exempts Certain Borrowers from Reductions.
    • Accountant Who Bungled Couple's Tax Return Couldn't Shift Blame to Their Attorney.
    • IRS Extends Replacement Period under Section 1033 for Certain Livestock Sales.
    • Prison Confinement Doesn't Excuse Failure to File Return or Make Election to Itemize.
    • IRS Finalizes Regs on Withholding on Periodic Retirement and Annuity Payments.
    • ABLE Regs Expand List of Individuals with Signature Authority over ABLE Accounts.
    • Couple Loses Deduction After Failing to Show Hours Spent on Rental Property by Others.
    • IRS Finalizes Income Tax Withholding Regs; Provides Optional Computational Bridge Entries.
    • IRS Finalizes Regs on Deductibility of Entertainment and Food or Beverage Expenses.
    • IRS Finalizes Regs Clarifying the Definition of Qualifying Relative for Years 2018-2025.
    • Couple's Lavish Spending Prevents Discharge of Taxes in Bankruptcy.
    • Taxpayer Filed a Valid Return, Despite Lack of Identity Protection PIN.
    • IRS Finalizes Eligible Terminated S Corporation Regulations.
    • Taxpayer Who Set up Nonprofit S Corporation Can't Pass Thru Losses.
    • Final Regs Address the Effect of Sections 67(g) and 642(h) on Trusts and Estates.
    • IRS Finalizes Bonus Depreciation Regs; Withdraws Partnership Look-Through Rule.
    • Fraud Conviction Overturned in Connection with Executive's 401(k) Withdrawals.
    • Minister Who Failed to Pay Self-Employment Taxes Can't Collect Social Security or Medicare.
    • Tax Court Disallows Losses from S Corp Transaction Due to Lack of Economic Substance.
    • Tax Court Rejects IRS Recharacterization of Stock Donation to Donor Advised Fund.
    • Eleventh Circuit Reverses Lower Court; Couple Can't Exclude Award from Income.
    • IRS Provides Q&A Guidance on Changes in SECURE Act and Miners Act.
    • IRS Notice on Payroll Tax Deferral Still Leaves Many Questions Unanswered.
    • SBA Loosens Loan Forgiveness Rules for Owner-Employees.
    • Taxpayer Partially Waived Work-Product Immunity by Disclosing Valuation Report to IRS.
    • Court Rejects IRS Attempt to Pierce Tile Contractor's Corporate Veil.
    • Taxpayers Substantially Complied with Requirements for Charitable Donation.
    • On Remand, Court Rejects President Trump's Challenge to Subpoena for His Tax Returns.
    • Seventh Circuit Affirms That Purported Loans Were Not Bona Fide Debt.
    • Debt Cancelled by Former Employer Was Ordinary Income, Not Capital Gain.
    • IRS Proposes Regulations on Extended Rollover Period for a Qualified Plan Loan Offset.
    • Business Groups Indicate That Many Members Will Not Defer Payroll Tax Withholding.
    • Using Property Management Company to Rent Properties Precluded Loss Deductions.
    • State Incentive Grants to Corporation Were Not Nontaxable Contributions to Capital.
    • IRS Issues Proposed Carried Interest Regs; Warns Against Circumventing Rules.
    • IRS Finalizes Regs on Charitable Donations Made in Exchange for Consideration.
    • Court Addresses Priority of Income Taxes Incurred in Year of Bankruptcy.
    • State Incentive Grants to Corporation Were Not Nontaxable Contributions to Capital.
    • Alimony and Payments to Divorce Lawyer Did Not Increase Basis of Marital Property.
    • IRS Issues Final Regs on Business Interest Expense Deduction Limitation.
    • IRS Simplifies Tax Accounting Rules for Small Businesses.
    • President Trump Signs Memorandum on Deferring Payroll Tax Obligations
    • Bankruptcy Trustee Can Avoid Tax Lien for Benefit of Bankruptcy Estate.
    • Taxpayer Should Not Have Been Precluded from Disputing Trust Fund Recovery Penalty.
    • Eighth Circuit Holds 30-Day Deadline for Filing a Tax Court Petition Is Jurisdictional.
    • IRS Proposes Redesigned Partnership Return for Tax Year 2021.
    • Mansion Was Capital Asset, Not Section 1231 Property, Despite Substantial Renovations.
    • Cancelled Debt Isn't Excludible from Income as Qualified Principal Residence Debt.
    • IRS Issues Final and Proposed Guidance on Recapturing Excess Employment Tax Credits.
    • IRS Provides Luxury Auto Depreciation Limits and Lease Inclusion Amounts for 2020.
    • Non-Willful FBAR Penalties Are Calculated Per FBAR Report, Not Per Financial Account.
    • Supreme Court Keeps Door Open for Congress to Subpoena President's Tax Returns.
    • Supreme Court: President's Tax Returns Are Fair Game for Criminal Subpoenas.
    • Tax Court Holds That Part of Taxpayer's Settlement Award Is Excludable from Income.
    • IRS Issues Guidance on Reporting Qualified Leave Wages Paid Under Families First Act.
    • President Signs Paycheck Protection Program Extension Act; New Deadline Is August 8.
    • CPA Sample Client Letter: Paycheck Protection Program Extension Act. .
    • Proposed Regs Address TCJA Changes to Transportation & Commuting Expenses.
    • Sec. 1031 Prop. Regs: Transfer of Incidental Personal Property Doesn't Taint Exchange.
    • Taxpayers Have Until August 31 to Roll 2020 RMDs Back into a Retirement Accounts.
    • IRS Expands Favorable Treatment on COVID-Related Retirement Plan Distributions.
    • SBA Clarifies Loan Forgiveness Limits for Owner Compensation; Releases New EZ Loan Forgiveness ...
    • Final 199A Regs Address Suspended Losses Included in Qualified Business Income.
    • Tax Court Petitions Delivered by a FedEx Service Not on the IRS's Formal List Were Untimely.
    • Tax Court Lacked Jurisdiction to Review Disallowed Section 1031 Exchange.
    • SBA Clarifies Loan Forgiveness Limits for Owner Compensation; Releases New EZ Loan Forgiveness ...
    • Tax Court: Transfers to Liquidating Trusts Did Not Result in Deductible Losses.
    • Proposed Regs Clarify the Definition of Qualifying Relative for Years 2018-2025.
    • Proposed Regs Address Deductibility of Certain Medical Care Payments.
    • Uncashed Check from Debtor's 401k Isn't Excludible from Bankruptcy Estate.
    • Tax Court Had Jurisdiction to Review Computational Adjustments in CDP Case.
    • Federal Circuit Reverses Claims Court for a Second Time on the Same Case; Couple Can Deduct ...
    • Tax Court Upholds Denial of Taxpayer's Qualified Residence Interest Deductions.
    • SBA Eliminates Cliff for Borrowers Using Less Than 60% of PPP Loans for Payroll Costs.
    • IRS Finalizes Rule Ending Donor Reporting Requirement.
    • Payments for Accounting Services Were Wages, Not Self-Employment Income.
    • IRS Delays Deadlines Applicable to Employment Taxes, Employee Benefits, and Exempt Orgs.
    • An In-Depth Look: The Paycheck Protection Program Flexibility Act.
    • CPA Sample Client Letter: Paycheck Protection Program Flexibility Act. .
    • New Guidance Clarifies PPP Loan Forgiveness Criteria and Calculations.
    • IRS Removes Section 385 Documentation Rules, But Keeps Distribution Rules.
    • Tax Court Reversed; Golf Course Doesn't Destroy Validity of Easement Contribution.
    • Tax Court Upholds Denial of Conservation Easement Deduction.
    • IRS Can Offset Chapter 7 Debtor's Overpayment Against Preexisting Tax Liability.
    • IRS Takes Whirlpool to the Cleaners in Case Involving Subpart F Income.
    • Proposed Regs Address Effect of Sections 67(g) and 642(h) on Trusts and Estates.
    • IRS Provides Relief Through Increased Flexibility for Taxpayers in Cafeteria Plans.
    • SBA Releases Complicated PPP Loan Forgiveness Application and Expanded FAQ.
    • IRS Provides Temporary Procedures for Faxing Certain Forms 1139 and 1045.
    • Court Disallows IRS Setoff in Farm Bankruptcy, but Can't Order IRS to Issue a Refund.
    • IRS Can't Offset Withheld Taxes Against Bankrupt Farm's Capital Gains Tax Debt.
    • Partnership Interest Was Includible in Gross Estate, Despite Transfer to Trust.
    • Prop Regs Address Calculation of UBTI for Exempt Orgs with Multiple Businesses.
    • No Deduction Allowed for Expenses Relating to Forgiven PPP Loans.
    • Contingency Involving Taxpayer's Child Precludes Alimony from Being Deductible.
    • Alternative Fuel Mixture Credit Did Not Apply to Taxpayer's Mixture of Butane and Gasoline.
    • IRS Extends Time to File Application for Tentative NOL Carryback Adjustment.
    • IRS Expands Filing and Payment Deadlines; Extends Time for Performing Certain Actions.
    • Congress Adds $310 Billion to Paycheck Protection Program; Businesses Get a Second Chance at ...
    • CPA Sample Client Letter: Paycheck Protection Program (PPP) - Additional Funding Available. .
    • Tax Court Rejects Taxpayer's Arguments for Higher Whistleblower Award.
    • Tenth Circuit Upholds Denial of Insolvency Exclusion for Discharged Debt Income.
    • IRS Issues Procedures for Waiving NOL Carrybacks.
    • Taxpayer's Farm Was Included in Gross Estate, Despite Purported Sale Before Death.
    • Individuals Can File Simplified Return to Claim CARES Act Recovery Rebates.
    • Procedures Issued for Deducting Qualified Improvement Property Depreciation for Prior Years.
    • Eleventh Circuit Upholds Denial of Taxpayer's Travel Expense Deduction.
    • IRS Provides Relief from Penalty for a Failure to Timely Deposit Employment Taxes.
    • No CDP Hearing for Couple Who Had Prior Opportunity to Dispute Tax Liability.
    • A Tax Practitioner's Guide to the Paycheck Protection Program (PPP). (Client Letter Included)
    • CPA Sample Client Letter: The CARES ACT - Paycheck Protection Program (PPP). .
    • In-Depth: A Tax Practitioner's Guide to the CARES Act. (Client Letter Included)
    • CPA Sample Client Letter: The CARES ACT - Individual and Business. .
    • President Signs Families First Coronavirus Response Act; Senate Passes $2 Trillion CARES Act. (Client Letter Included)
    • CPA Sample Client Letter: The Families First Act and The CARES Act.
    • Deadline for Income Tax Returns and Payments Postponed to July 15 due to COVID-19.
    • CPA Sample Client Letter: Coronavirus-Related Postponement of Tax Deadlines. .
    • Section 7508A(c) Provides Exception to Limitation on Interest on Overpayments.
    • CPA's Serious Illness Did Not Excuse Couple's Failure to File Tax Return on Time.
    • Supreme Court Strikes Down Rule for Allocating Tax Refunds Among Members of Consolidated Groups.
    • IRS Provides Tax Relief for Certain Foreign Trusts and Steps for Requesting Refunds.
    • Basis and At-Risk Loss Rules Apply in Determining Partner's Self-Employment Tax.
    • Tax Preparer Wins Costs and Fees after Prevailing in Action for Refund of Penalties.
    • Tax Court Rejects Constitutional Challenge to Early IRA Withdrawal Penalties.
    • High-Deductible Health Plans Can Cover Coronavirus Costs.
    • Court Orders Trial on Amount of Income Taxpayer Received in Counterfeit Check Scheme.
    • Retirement Funds Received in Divorce Settlement Were Not Exempt in Bankruptcy.
    • Taxpayer's Extravagant Lifestyle Prevents Tax Debts from Being Discharged.
    • Prop. Regs Address Federal Income Tax Withholding and Redesigned Form W-4.
    • Taxpayer's Guarantees on Loans to Related Businesses Entitled Him to Deduct Losses.
    • IRS Issues Uniform Capitalization Guidance for Farmers.
    • Proposed Regs Address Deductibility of Entertainment and Food or Beverage Expenses.
    • District Court Properly Denied Tax Protester's Request for Competency Hearing.
    • Conservation Easement Deduction Fails Due to Donor's Retained Development Rights.
    • Statute Began to Run on Date Returns Were Filed, Not on Date Taxpayer Lied to IRS.
    • Requests for Tax-Exempt Status Must Now Be Filed Electronically.
    • What to Do About Missing Forms W-2 and Forms 1099.
    • Certain Payments to Acquire Auto and Equipment Leases Must be Capitalized.
    • Final Regs Increase Maximum Value for Personal Use of Employer-Provided Vehicles.
    • Trust Fund Recovery Penalties Are Subject to Written Supervisory Approval Requirement.
    • Former Congressman's Conviction for Filing False Tax Return Affirmed.
    • Supervisory Approval Required for Listed Transaction Penalty.
    • Late Filing Penalty Did Not Apply Where Estate Tax Was Paid Before Extended Due Date.
    • Seventh Circuit: Medication-Induced Compulsive Gambling Is Not a Disability Excusing Penalty on ...
    • IRS Provides Additional Debt Relief for Certain Student Loan Borrowers.
    • Office of Chief Counsel: Relief for Failing to Timely File a Partnership Return Has Not Become ...
    • IRS Did Not Formally Communicate a Penalty Determination Before Issuing a Notice of Deficiency.
    • Tax Court Addresses Burden of Production in Penalty Supervisory Approval Cases.
    • Donors of Items Salvaged from Deconstructed Home Failed to Substantiate Donations.
    • Executor Who Transferred Estate Assets Held Personally Liable for Unpaid Estate Taxes.
    • IRS Supervisory Approval Required Before First Formal Communication of Penalties.
    • S Corporation ESOP Did Not Qualify Due to Operational and Form Failures.
    • Foreign LLC's Income Is Not Exempt from U.S. Tax under U.K. - U.S. Treaty.
    • District Court Allows Lawsuit Challenging IRS Rulemaking Procedure to Go Forward.
    • Third Circuit Upholds Tax Evasion Convictions, but Reverses Restitution Judgment.
    • Russian Citizen's Wages Are Exempt from U.S. Tax under U.S. - Russia Treaty.
    • Taxpayer Improperly Used Installment Method to Report Mobile Home Sales.
    • Final Regs Address Foreign Withholding Rules.
    • Business, Medical, and Moving Standard Mileage Rates Decrease for 2020.
    • Fifth Circuit Affirms ACA Individual Mandate Is Unconstitutional; Severability Question Remains.
    • Top Tax Developments of 2019.
    • IRS Finalizes Foreign Tax Credit and Other Foreign-Related Regulations.
    • Final Section 355(e) Regs Apply to Synthetic Spin-offs.
    • MoneyGram Can't Take an Ordinary Loss on Worthless Securities.
    • Employers' Cash Reimbursements for Malfunctioning Transit Cards Are Taxable Income.
    • Tax Court Upholds Worthless Security Deduction in Year Company Began Winding Down.
    • Proposed Regs Clarify Rules on Charitable Donations and State Tax Considerations.
    • In-Depth Analysis of Year-End Tax Act. (Client Letters Included)
    • IRS Postpones Reporting Capital Accounts on Tax Basis.
    • Appropriations Bill Includes Tax Extenders and Numerous Other Tax Provisions.
    • Currency Option Trades Lacked Economic Substance; Resulting Losses Are Disallowed.
    • 5 Percent, Not 35 Percent, Penalty Applies to Late Reported Foreign Trust Distributions.
    • No Bad Debt Deduction for Payment Properly Characterized as Capital Contribution.
    • Final Estate Regs Address Application of Increased TCJA Basic Exclusion Amount.
    • Losses from Taxpayer's Cutting Horse Activity Deductible Despite Long History of Unprofitability.
    • IRS Updates Per Diem Substantiation Methods for TCJA Changes.
    • Taxpayers Can't Sue to Stop IRS from Receiving Privileged Info from Former Attorney.
    • IRS Updates Rev. Proc. for TCJA Changes to Auto and Moving Expense Deductions.
    • Federal Circuit Upholds $803,000 Penalty for Willful FBAR Violation.
    • IRS Releases Retirement-Related COLAs; 401(k) Contribution Limit Increases to $19,500.
    • Partnership's Reporting of Partial Gain Was Enough to Preclude Extension of Statute.
    • Proposed Regs on Eligible Terminated S Corporations Introduce New Priority Rule for Sourcing ...
    • IRS Issues Inflation-Adjusted Amounts for 2020.
    • Seventh Circuit Reverses Course on Allowing Circumvention of Appeal Deadline.
    • Ambiguous IRS Notice Sinks Taxpayer's Tax Court Petition.
    • Court Nixes $155 Million Conservation Easement Deduction Due to Faulty Deed Provisions.
    • Tax Court: No Deductions Allowed for Medical Marijuana Businesses, Including Those Operating ...
    • IRS Can't Offset One Taxpayer's Deficiency Using a Related Taxpayer's Overpayment.
    • 2019 Year-End Tax Planning Guide for BUSINESSES. (Includes Sample Client Letter).
    • CPA Sample Client Letter: 2019 Year-End Tax Planning for BUSINESS.
    • An In-Depth Look: Practitioner's 2019 Year-End Tax Planning Guide for INDIVIDUALS. (Includes Sample Client Letter)
    • CPA Sample Client Letter: 2019 Year-End Tax Planning for INDIVIDUALS.
    • Cooperative's Payments to Members Were Per-Unit Retain Allocations for Section 199 Purposes.
    • Federal Circuit: Lower Interest Rate on Refunds Applies to Nonprofit Corporations.
    • Court Finds That Taxpayer's Letter to IRS Was a Timely Filed Informal Refund Claim.
    • IRS Issues Second Draft of Form 1040 and New Form 1040-SR.
    • S Corporation's AAA Resets to Zero after a Post-Termination Transition Period.
    • Finder's Fee Paid in Connection with Merger Was Not a Deductible Business Expense.
    • IRS Issues Draft Instructions for Qualified Business Income Deduction.
    • IRS Issues 2019-2020 Special Per Diem Rates.
    • Employer's Failure to File Form 945 Prevents Statue of Limitations from Applying.
    • Appeals Court Rejects Tax Fraud Restitution Order Due to Sloppy IRS Substantiation.
    • Taxpayer Not Entitled to Itemized Deductions on Substitute Return Filed by IRS.
    • IRS Extends Replacement Period under Section 1033 for Certain Livestock Sales.
    • IRS Issues Draft 2019 Forms 1065, 1120-S, and Schedules K-1.
    • District Court Upholds TCJA Limit on State and Local Tax Deductions.
    • IRS Finalizes Regs on Partnership Disguised Sales and Recourse Liabilities.
    • Final Regs Modify Qualifications for a 401(k) Hardship Distribution.
    • Taxpayer Was Entitled to Business Bad Debt Deduction for Unrepaid Loan.
    • New Bonus Depreciation Proposed Regs Issued.
    • IRS Finalizes Bonus Depreciation Regs; Clarifies Expansion of Qualifying Property.
    • IRS Expands and Finalizes Section 199A Safe Harbor for Rental Real Estate.
    • Tax Return Photocopies Aren't Subject to Frivolous Return Penalties.
    • Court Denies Motion to Expedite Lawsuit to Compel Production of President's Tax Returns.
    • Penalty Relief Provided to Exempt Orgs That Relied on Revenue Procedure 2018-38.
    • Rental Properties Subject to Management Agreements Can't be Grouped with Other Rental Activities.
    • Draft Instructions for Calculating QBI Deduction Provide Additional Guidance.
    • No Casualty Loss Deduction for Stigmatization Resulting from Flood Damage.
    • Court Rejects IRS's Classification of Partnership Interest Expense as Investment Interest.
    • Proposed Regs Implement TCJA Changes to Code Section 451 for Accrual Method Taxpayers.
    • IRS Settlement Officer Acted Unreasonably in Closing Taxpayer's CDP Case.
    • IRS Provides Relief for Domestic Partnership and S Corp Filings Under GILTI Regs.
    • Proposed Regs Increase Maximum Value for Personal Use of Employer-Provided Vehicles.
    • Taxpayer Failed to Make Delinquent 401(k) Loan Repayments Within Grace Period.
    • IRS Automatically Waiving 2018 Estimated Tax Penalty for More Than 400,000 Tax Filers.
    • Tax Court Addresses Gift Tax Valuation of Interdependent Closely-Held Companies.
    • Taxpayer Could Not Exclude Uncashed Check for a Qualified Retirement Plan Distribution from Income.
    • Fair Market Valuation Method Does Not Include an Exception for Fraudulent or Criminal Actions ...
    • District Court Invalidates Regulation Defining Educational Organizations.
    • Tax-Exempt Status Denied for Entity Operating as a Conduit to Generate Sales Leads.
    • Court Strikes Down IRS Rule That Eliminated Exempt Organization Donor Reporting.
    • Developer's Payments for Marketing Materials Were Nondeductible Bidding Costs.
    • IRS Allows Taxpayers to Revoke or Make Late Bonus Depreciation Elections.
    • Fourth Circuit Rejects Challenges to U.S.-Canada Tax Treaty.
    • Chief Counsel's Office Addresses Effective Date and Scope of Casualty Loss Limitation.
    • IRS Grants 6-Month Extension for Filing Forms 1065 to Certain Partnerships.
    • No Bonus Depreciation Deduction for Rehabilitation of Burned Agricultural Property.
    • IRS Releases Draft of 2019 Form 1040; Revises Drafts of Form 8895 and Form 8995-A.
    • D.C. Circuit: 30-Day Period for Whistleblower Appeals Is Not Jurisdictional.
    • Army Officer Not Entitled to Foreign Earned Income Exclusion While in Afghanistan.
    • CPA Penalized for Aiding and Abetting Tax Understatements on More Than 5,000 Tax Returns.
    • IRS Reminds Combat Veterans to File for Tax Refunds on Disability Payments Reported as Income.
    • Late IRA Rollover Was Not Taxable Due to Bank's Bookkeeping Error.
    • Final Regs Permit Employers to Use Truncated Taxpayer ID Numbers on Form W-2.
    • No "Away from Home" Travel Deductions Allowed for Contract Employee.
    • Tax Court Lacked Jurisdiction Because No Notice of Determination Was Issued.
    • Early Withdrawal Did Not Render Debtor's Annuity Nonexempt in Chapter 7 Bankruptcy.
    • Author's Royalty Income from Publishing Contracts Was Subject to Self-Employment Taxes.
    • Farm in Chapter 11 Bankruptcy Can't Convert to Chapter 12 to Obtain More Favorable Treatment of ...
    • District Court Applied Wrong Definition of "Willful" in Return Preparer Penalty Case.
    • Eleventh Circuit Reverses District Court, Upholds Taxpayer's Sec. 1341 Refund Claim.
    • Final Regs Address Employment Taxes for Disregarded Entities Owned by a Partnership.
    • Return Preparer's Fraud Suspended Couple's Statute of Limitations on Assessment.
    • IRS Guidance Addresses Section 199A W-2 Wage Calculation for Certain Co-ops.
    • Pastor Couldn't Exclude Payments as Parsonage Allowances or Gifts from Congregants.
    • IRS Issues Proposed Section 199A Regs for Cooperatives and Their Patrons.
    • IRS Finalizes Regs on ESBTs with Nonresident Aliens as Potential Current Beneficiaries.
    • IRS Provides Safe Harbor for Charitable Donations Made In Exchange for SALT Credits.
    • IRS Finalizes Regs Limiting Contributions in Exchange for State Tax Credits.
    • Final Regulations Expand Use of Health Reimbursement Arrangements.
    • Congress Passes IRS Reform Act with Bipartisan Support.
    • Shareholders of Closely Held Corporation Were Liable as Transferees.
    • IRS Failure to Verify Mailing of Notice of Deficiency Was Abuse of Discretion.
    • Tax Court Nixes Assessment of Trust Fund Recovery Penalty (TFRP).
    • D.C. Circuit Upholds Tax Court's Denial of Charitable Deduction for Remainder Interest.
    • Eleventh Circuit Allows Injunctive Relief for IRS to Collect Unpaid Employment Taxes.
    • IRS Provides Luxury Auto Depreciation Limits and Lease Inclusion Amounts for Autos Placed in ...
    • IRS Releases Draft of Newly Designed Form W-4 for Use in 2020.
    • Foreign-Owned Charter Yacht Not Off the Hook for Employment Taxes.
    • Third Circuit Rejects Challenge to Controlled Foreign Corp Loan Guarantee Regs.
    • Proposed Regs Address Withholding on Transfers of Partnership Interests Involving Foreign Persons.
    • CFO Was Responsible for Employment Taxes, Notwithstanding Government Receivership.
    • IRS Offers Reasonable-Cause Relief for Returns Affected by CCH Software Outage.
    • Eleventh Circuit Holds Shareholder Did Not Have Basis in Indirect Loans to S Corp.
    • Couple Could Claim Credits Based on Medicaid Waiver Payment Excluded from Income.
    • Former S Corp Must Reduce AAA for Distribution in Post-Termination Transition Period.
    • Sixth Circuit Reverses District Court; Wrongful Levy Action Was Not Time Barred.
    • IRS Can Use Lien and Levy Powers to Collect Criminal Restitution Amounts.
    • Distributions of Casino Revenue Are Taxable to Native American Tribe Members.
    • Where No Disclosure Is Required, There Is No Statute for Assessing Section 6707A Penalty.
    • Tenth Circuit: IRS Can Make Initial Determination of Penalty After Issuing Notice of Deficiency.
    • Federal Circuit Holds That Excess State Tax Credit Was Taxable Income.
    • IRS Can Assess FBAR Penalty Based on Number of Accounts Rather Than Number of Filings.
    • Tax Court Addresses Deductibility of Business Owner's Settlement Payment.
    • CPEOs Can't Be Used to Transform Self-employed Individuals and Partners into Employees.
    • IRS Provides Safe Harbor for Pro Sports Teams' Trades of Personnel Contracts and Draft Picks.
    • Timely Mailing Rule in Code Section 7502 Trumps Common-Law Mailbox Rule.
    • IRS Addresses Interplay of State Tax Limitation and Home Office Deduction.
    • IRS Issues Proposed Regs on Investments in Qualified Opportunity Zones.
    • Two-Percent S Corp Shareholders by Attribution May Deduct Health Insurance Costs.
    • Proposed ESBT Regs Clarify Tax Treatment of TCJA Changes.
    • IRS Releases Draft 2019 Forms for Section 199A Deduction, Expands 199A FAQ.
    • Treasury Department Promises Not to Seek Judicial Deference for Subregulatory Guidance.
    • IRS Action for Unpaid Estate Taxes Not Barred by State Statute of Limitations.
    • Taxpayer's Bill of Rights Does Not Provide Grounds for Challenging a Notice of Deficiency.
    • Taxpayer Acquired Beneficial Ownership of S Corporation in Divorce.
    • District Court Addresses Valuation of Minority Interest Stock for Gift Tax Purposes.
    • Fifth Circuit: Settlement Payments Relating to Death of S Corp Owner's Girlfriend Aren't Deductible.
    • IRS Clarifies Tax Treatment of State and Local Tax Refunds.
    • Ninth Circuit: Estate Overstated Amount of Charitable Deduction.
    • D.C. Circuit Reverses District Court, Upholds PTIN Fee on Tax Return Preparers.
    • TIGTA Releases Report on Code Section 199A Qualified Business Income Deduction.
    • Penalty for Late Filing of S Corporation Does Not Require Supervisor Approval.
    • Indian Tribal Corporation Not Liable for the Employment Taxes of Its Legally Distinct Division.
    • CFC Partners of U.S. Partnership Had to Increase E&P for Subpart F Income.
    • Computer-Generated Penalty Exempt from Written Supervisory Approval Requirement.