A Brief Introspection of Repair vs. Improvement: IRS Revenue Procedures 2014-16 and 2014-17

That’s right Y’all this is another one of those quite game changers for owners of tangible property concerned about keeping the IRS at bay by actually adhering to the specific US Tax Code and subsequent IRS Revenue Procedures. My apologies for being so brazen but I more than most appreciate the fact the the IRS compliance…

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US v. Clarke SCOTUS Decision Favors Taxpayers

The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that… “a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly raising an inference of bad faith.” JUSTICE KAGAN delivered the opinion of the Court as follows.…

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US v. Clarke SCOTUS Decision Favors Taxpayers

The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that… “a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly raising an inference of bad faith.” JUSTICE KAGAN delivered the opinion of the Court as…

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IRC 1014 & the Significance of Stepped Up Basis in Estate Planning

According to Internal Revenue Code Section 1014 the basis of property acquired from a decedent is the fair market value of the property at the date of the decedent’s death. This is often referred to as stepped up basis and it is profoundly significant for US taxpayers dealing with the myriad of issues surrounding estate planning…

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Defending Against Alter Ego Allegations

What is an “alter ego” allegation? Aside of course being one of several nuanced yet distinct stages of intoxication, when it comes to the IRS it seems from my perspective that there are several elements of the alter ego doctrine that arose out of the California Supreme Court in Minifie V. Rowley, 187 Cal 481,…

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IRC 7216 Disclosure Issues to Consider When Selling Your Practice – Start With A Tight NDA

As many of you know who follow this blog I also currently serve in a voluntary capacity as the President of the Colorado Society of Enrolled Agents, a state affiliate chapter of the National Association of Enrolled Agents. In this capacity I have been blessed with the opportunity to connect with many different tax practitioners…

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Tangible Assets Used In Converting Corn To Fuel Grade Ethanol Are Properly Included In Asset Class 49.5

A certain important person in my reality – my wife – is becoming increasingly interested in the business end of biomass refineries. You go girl. Funny but this interest also happens to correlate with a new file I am developing involving a farmer who owns an ethanol plant so hopefully we will be taking another…

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Buying or Selling Business Assets – Remember to File IRS Form 8594 & Avoid Future Headaches

Buying and selling business assets can be complicated.  The last thing you want – BELIEVE ME – is the hassle of explaining inconsistent treatment of the sale for tax purposes  3 YEARS INTO THE FUTURE. Avoiding this is simply accomplished by remembering to file one extra tax form. Basically the US tax law requires both…

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Taxation of Social Security Benefits

A good friend of mine, Bruce Larsen of Presidential Brokerage recently published an outstanding report on the Taxation of Social Security Benefits. One of the many things I like about Bruce is that he is passionate about all aspects of Social Security. He is my go to resources on all matters in these regards. As…

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