Odujinrin v. IRS Commissioner Reinforces the Significance of Engaging a Reputable Enrolled Agent

In Wole Odujinrin v. IRS Commissioner the petitioner, a hematology oncologist who represented himself, did not have adequate substantiation to support his petition and was not entitled to claim a net operating loss. He was also liable for an accuracy-related penalty under IRC 6662 – the expensive kick in the shorts. This petitioner moronically showed up with little…

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How to Calculate Basis of a Primary Residence Converted to Rental Property [Reg. §1.168(i)-4(b)] [Reg. §1.165-9(b)(2)]

Many people have built impressive residential real estate portfolios one property at a time, living in the property while fixing it up thus declaring it their primary residence for income tax purposes and then moving onto a new house to fix up and subsequently rent out, and repeat. Several of my friends in Colorado, Minnesota…

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Worker Classification & the Colorado Department of Labor & Employment CRS 8-70-115

This post is about my experiences with C.R.S. 8-70-115 as they pertain to the Colorado Employment Security Act of 2013.  First off let me start by saying that there are some really good hard working bureaucrats paid by our tax dollars working inside the Colorado Department of Labor & Employment.  Unfortunately like most all organizations for every…

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Tax Implications of US Expatriation; Internal Revenue Code 877A

I was brought in on another interesting file this week involving a US Citizen seeking expatriating that I was strongly advised to run away from by my mentors and friends simply because it is easy to paint a picture of prospective expatriation as having a criminal intent and I am not a criminal lawyer (thank you…

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New Information on US – Canada Income Tax Treaty

There are a LOT of people from Canada in Denver, Colorado where I spend the majority of my time as a student of the US tax code.  Many dual citizens got stung by the reasonably new US FBAR tax laws and there were some tragic cases that filtered there way up to my desk.  Having…

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What is an FTE? What is a Seasonal Employee?

My friend, confidant, mentor and expert in the procedural ramifications of ObamaCare, Debbie Nash of D. Nash & Associates, got to talking with me about some of the nuances of this legislation and our discussion quickly digressed into what the definition is of a ‘Full Time Equivalent’ (FTE) employee for IRS tax purposes. One of…

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Tax Considerations When Supporting Parents

As I have been helping my Mom transition into life as a widow many interesting facts have begun to resonate. Particularly intriguing for me today under Regs. §1.2-2(b)(4) parent(s) can be claimed as a dependent if you meet the usual support, citizenship, gross income, and joint return tests. Interestingly enough if you are single you can file…

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Basic Steps to Avoiding Probate

As many of you know that follow this blog my father recently passed away and I’ve been called upon to settle his financial affairs. My biggest fear is probate and after studying the tax code I have grown to be of the opinion that it is best to be avoided when possible. This short post on the…

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Denver IRS Practitioner Meeting July 2014 – A Summary Review with Excellent References for FBAR and FinCEN Matters

Meeting Summary as produced by IRS Senior Stakeholder Liaison Deborah Rodgers Nancy Carver, IRS Local Area Counsel Counsel continues to assist in training employees on partnership audits, and TEFRA. Counsel is also assisting in the investigations of promoters. Virtual currency is on the radar for Internal Revenue Service. Controlling ID Theft is a task that…

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