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Tax Articles

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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Use IRS Form 8082 to Report An Incorrectly Issued K1

I’ve been working a very complicated file since my last post involving income in 11 states and countless K-1s, Partner’s Share of Income, Deductions, Credits, etc. Interestingly enough one of my trusted lieutenants noticed that one of the K-1s from one of the partnerships incorrectly reported a gain on the sale of a partnership asset as a…

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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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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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Decoding the IRS – Document 6209

Understanding what you are up against with the IRS can be frustrating on many levels. When it comes to the terminology they throw around, especially acronyms, what you will find is that even seasoned veterans quite often pull out specialty reference manuals or what I often refer to as code books.  This post is intended…

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