seal

Tax Article Archives

Read about some of John’s more memorable experiences navigating the unchartered areas of the Internal Revenue Code.

View articles

mountain

I Need Help Now!

Directly Contact John via his contact form or call 720.234.1177

Read more

john

Ask a Question

Ask John a question and get a written response same day.

Ask a Question

Tax Articles

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…

Details

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…

Details

LLC Income is INDEED Subject to Self Employment Tax: IRS Chief Counsel Advice 201436049

In 1997, the IRS issued proposed regulations governing when the distributive share of partnership income for Limited Liability Company (LLC) members was to be included in self-employment income. It basically advised that an LLC member would be treated as a limited partner — and thus the distributive share would NOT be self-employment income– unless the…

Details