Abusive tax shelters of every nature are what I call scum bag lawyer schemes. It is difficult to specifically define abusive tax shelters because new ones are constantly emerging. Essentially they are arrangements usually designed by 'promoters' to circumvent tax laws or evade taxes. They...
Okay I got a new case for appeal consideration and am blasting out my thoughts as to why this one is not receiving further consideration. In short it is not winnable. You need to be very diligent in your research and documentation to successfully deduct...
IRS Notice 2011-68 provides interim guidance on the federal income tax treatment of annuity and life insurance contracts with a qualified long-term care insurance (QLTC) feature. The guidelines address the application of certain changes to the federal income tax rules governing annuity and life insurance contracts as...
A friend of mine asked me to blog today about my experiences from a tax perspective with Ponzi schemes and pyramid schemes. Both are for the most part perpetrated by clandestinely malcontent people that have inadvertently grown trustworthy, a "friend" or relative or fellow member of...
Generally you can deduct expenses paid for medical care for yourself, your spouse and your dependents to the extent the total expenses for the year exceed 7.5 percent of your adjusted gross income and you itemize your deductions (Schedule A). IRS Pub. 502, Medical and Dental Expense, has valuable...
Taxpayers who own shares in an S corporation are allowed pass-through losses to the extent of their basis (also commonly referred to as investment) under §1366(d) in their entity. Shareholders can obtain basis in a variety of ways such as direct investment, loaning the corporation money, contributing...
The Small Business Jobs Act of 2010 is amazingly complex legislation. Some pundits estimate that the provisions offering tax relief will actually 'cost' up to $12 billion. These tax cutting measures were I believe intended to offer incentive to businesses to make investments in plant, property, more...
According to a report filed by the Treasury Inspector General for Tax Administration there has been a 19 % increase of enforcement personnel serving in the Collection and Examination function of the IRS since Fiscal Year 2006. Whereas on average overall IRS staffing increased 4 percent during...
In reviewing James F. Moss, et ux. v. Commissioner 135 TC No. 18 to be a real estate professional, a taxpayer must meet two requirements: (1) More than one-half of the taxpayer’s personal services must be performed in real property trades or businesses in which he materially participates; and (2) The taxpayer must perform...
The IRS developed 14 criteria to evaluate applications for church foundation status. If a church does not meet these criteria, it will not receive tax exempt status. The criteria are weighted with the four most important of these being: • A complete organization of ordained ministers ministering to their congregations. • The...