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Tax Articles

What is an ITIN? T.D. 8671, 1996-1 C.B.314

In 1996, the U.S. Treasury Department issued T.D. 8671, 1996-1 C.B.314 introducing the ITIN – Individual Taxpayer Identification Number – requiring people foreign to the USA to use a unique identification number on their United States federal income tax returns. These regulations were intended to address concerns by the IRS and elected officials that without a unique…

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Why to Revoke An S Election and How to Do It – Internal Revenue Code Section 1362(d); Reg § 1.1362­6(a)

Many entrepreneurs get caught up in selecting the “most appropriate business structure” – particularly people planning to conquer the moon right out of the gate. If this is you beware as business structure is a determination that is best driven out of operational efficacy. Why? Most all new businesses fail, it is a fact of life. Properly…

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Meal Expense – Navigating Between Internal Revenue Code Sections 162, 274, 132; IRS Technical Advice Memorandum 200030001; and, Churchill Downs v. Commissioner

As per usual I’m swimming in areas where the tax code is seemingly at odds. The latest matter across my desk regards meals and entertainment (M&E) expense. These are the two questions at hand: Specifically at what point does a meeting expense incurred under IRC section 162 to present a sales pitch to groups of prospective investors…

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Richard S. Leyh et ux. v. Commissioner – Contemporaneous Log Detailing Rental Property Activity Permissible in Defining Real Estate Professional for Income Tax Purposes

Richard S. Leyh et ux. v. Commissioner (T.C. Summ. Op. 2015-27) details a case in which a taxpayer could revise her contemporaneous log of daily rental property activity and qualify as a real estate professional for income tax reporting purposes. When the IRS audited the taxpayer’s 2010 return, the log totaled 632.5 hours spent in…

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