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Tax Articles

What is a ‘Qualifying Relative’ for US Tax Purposes: IRC 152

Wading through the convolution required to identify specifically who qualifies as a relative for income tax reporting purposes oftentimes can be difficult, not because the actual tax code is difficult to understand in these regards or even subject to much interpretation.  No, it is difficult because the subject matter is best addressed with discretion gained…


Tax Implication of Publicly Traded Partnerships: Why Purveyors or the US Tax Code Snarl at Investment Brokers

My friend Roger Botterbusch recently put together a most excellent presentation on the tax implications of owning Publicly Traded Partnerships (PTPs), also commonly referred to as Master Limited Partnerships (MLPs). As a result I developed a new profound distaste for investment brokers pedaling these things for their ‘prospective’ fat returns whilst simultaneously poo-pooing the heavy, heavy…


IRS Released “Get Transcript” Application for Real Time Downloading of Information on Your Tax Account

Any individual taxpayer can view, print or download their own transcripts on-line in Real-Time using a computer or Smart Phone. You simply go to and enter  GET TRANSCRIPT in the site search bar, OR … Click here –>! This is a giant leap forward for working with the IRS. Once in their system a…


IRS Stakeholder Liaison Meeting – Denver

The following is a summary of the IRS’ most recent Stakeholder Liaison Meeting in Denver Colorado as prepared by Ann Burton, IRS Senior Stakeholder Liaison.  It is jam packed with procedural information and status updates from line managers and group leaders of the various IRS operational functions including Collections, Examinations, Appeals, Tax Court etc.  A…


2014 Tax Fears & Advice

With my family snugly content midst a long holiday season I felt compelled to pen some thoughts regarding the ubiquitous US Tax Code and all its myriad of seemingly scary changes looming around the proverbial corner. This post lists 10 tax matters to be aware of in the new year that have come up in…


TAS – The Decline and Fall of a Once Great Department Inside the IRS

Last week I read that the Taxpayer Advocate Service’s (TAS) case load has been growing substantially and this once great department inside the IRS does not have the resources to continue to handle its current inventory levels without adversely impacting its ability to provide effective service. As a result, IRS memorandum TAS-13-0913-009 was produced to reissue guidance…


The Intersection of ‘Trafficking under IRC 280(E)’ & Cost of Goods Sold (COGS) Relevant to Taxable Income for Marijuana Distributors in Colorado

As many of you who follow me and/or this tax blog know I have been actively tracking a handful of select medical marijuana dispensaries in Colorado who have been denied the opportunity to deduct ordinary and necessary business expenses by the IRS when arriving at net income subject to income tax. One of the first…


Colorado Disaster Relief from the IRS – Publication 2194

If you have been impacted by a disaster in your area like many of my friends most recently here in Colorado due to flooding as defined by FEMA and identified by our President causing you to be unable to meet your tax obligations the IRS may be able to assist you with payment and filing extensions,…


General Rules for S-Corporation Distributions A Random Walk Down IRC 1368

Unless you elect different treatment, for shareholder income tax purposes S corporation distributions are applied in the following order: 1. To reduce the Accumulated Adjustment Account (AAA) determined without regard to any net negative adjustment for the tax year but not below zero. According to IRC 1368 if distributions during the tax year exceed the AAA…


IRS Office of Appeals Handling Of Collection Due Process Cases – STILL INADEQUATE!

If you have ever been a victim of IRS lien or levy action you know first hand that it can be unilaterally devastating on many levels and take literally years if not decades to financially overcome. To add insult to injury it gets all the more complicated when the IRS action is taken before you’ve…