Uncertain Tax Position Archives - John R. Dundon II, Enrolled Agent
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Uncertain Tax Position

As per usual I'm swimming in areas where the tax code is seemingly at odds. The latest matter across my desk regards meals and entertainment (M&E) expense. These are the two questions at hand: Specifically at what point does a meeting expense incurred under IRC section 162...

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...

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...

The best free US tax research sites in my opinion are: 1. For actually referencing the US Tax Code - Cornell University Law School as they seem to do the best job with updates and maintenance and at the end of the day the only thing...

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...

Check out the following 5 lessons I learned this week regarding IRC 351 nonrecognition transactions: 1. The basis assigned to stock received generally is the same as the basis in the property transferred to the corporation. If however you also receives boot from the corporation your...

The distinction of how this is possible distills down to understanding the nuanced difference between a 'Continuous' and a 'One Time' IRS tax levy. Under Code Sec. 6331(h) once a tax levy is approved, the effect of the levy on specified payments received by a taxpayer is...

According to IRS administrative guidelines to its examiners concerning Rev. Rul. 2012-18, published in the 2012-26 Internal Revenue Bulletin, when performing a tip examination (aka audit), IRS examiners must ensure that service fees or charges are properly characterized as wages and not tips. If the payment is...

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