Under §165, in general, the basis of a partnership interest equals the sum of the amount of money contributed, the partner’s share of partnership liabilities and the partner’s distributive share of partnership income and losses. How to compute the adjusted basis of the partnership interest when there is an initial contribution to...
The following report was issued by the Treasury Inspector General for Tax Administration (TIGTA) on August 15, 2011 and it basically says that which many of us already know, the IRS Office of Appeals needs help with Collection Statutes Expiration Dates (CSED). In my opinion...
I have been developing quite an expertise in resolving Net Operating Loss carry back matters yet with each new situation there is something new that seems to be discovered. IRC section 6511(d)(2) states, a claim for credit or refund that corresponds with an over payment attributable...
The Internal Revenue Service (IRS) is not formally evaluating its enforcement employees’ job performance based on quotas or other records of tax enforcement results, according to a new report from the Treasury Inspector General for Tax Administration (TIGTA) contrary to the opinion of many. The IRS...
I've been getting asked this question quite a bit so I put it directly to the IRS. My guess is that I wasn't the only one who asked because today the Internal Revenue Service issued guidance designed to clarify the tax treatment of cell phones. The...
Under IRC §170(c)(2)(A) generally speaking when a trust uses its income to buy an asset and in a later year gives that asset to a charity it is allowed a charitable deduction. Chief Counsel Advice 20104202 stipulates however that if the deduction was not limited to the trust’s...
It has been truly amazing to see so many failed payroll service providers all around the United States screw over small business owners by collecting tax revenue from business owners to be passed on to federal and state governments and then fail to turn the...
According to Tax Court Memo 2010-261, a husband and wife purchased real estate, refurbished it and reported the sale on Form 4797. They contended the homes were purchased for use as rentals; however, over the three-year period at issue, none of the homes were rented. The IRS determined that...
In the Tax Court case of Trieu M. Le, et ux. v. Commissioner TC Summary Opinion 2010-94 the IRS took the position that the taxpayer was a casual gambler and should have deducted his losses up to his winnings on Schedule A. The taxpayer took the...
Section 152(e) of the tax code specifies how to determine the dependent status of children of divorced parents. This code section states that the noncustodial parent can claim the dependency exemption for a child when the custodial parent signs a written declaration that the custodial parent will not claim such child...
