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TAX RESEARCH ARTICLES ARCHIVED

Taxpayer's Estate Owes Luxury and Gas Guzzler Taxes on Exotic Imported Car. 05/14/2014

Automatic Consent for Certain Sales-Based Royalty & Vendor Chargeback Method Changes. 05/12/2014

Legal Fees to Fight Class Action Suit Were Nondeductible Capital Expenses. 05/12/2014

Taxpayer Uses Mitigation Rules to Obtain Refund from Closed Tax Year. 05/09/2014

Court's Rejection of IRS Position on Horse-Related Activity Saves Taxpayer $800,000. 05/08/2014

Taxpayer Can't Deduct Repayment to Mother for Unauthorized Stock Purchases. 05/02/2014

Adult Care Facility Worker Was an Employee, Not an Independent Contractor. 05/01/2014

Estate Beneficiary Doesn't Qualify for First-Time Homebuyer Credit. 04/30/2014

President Signs into Law New Funding Rules for Certain Cooperative and Charity Plans. 04/29/2014

Father Was Custodial Parent Despite Conciliation Agreement's Terms. 04/28/2014

Doctoral Student's Fellowship Grant Is 100 Percent Taxable. 04/27/2014

Foreclosure Is a Fully Taxable Transaction for Purposes of Passive Loss Rules. 04/26/2014

Horse Owner Materially Participated in Horse Breeding and Racing Operation. 04/25/2014

IN-DEPTH: Interpretation of At-Risk Rules on LLC Debt Guarantees. 04/24/2014

Virtual Currency Treated as Property for Tax Purposes. 04/11/2014

Tax Court Holds That a Trust Can Qualify for Rental Real Estate Exception. 04/11/2014

Preparing a Tax Return for a Disabled Veteran - A Step by Step Guide. 04/01/2014

IN-DEPTH: Failure to File Joint Return Precludes Rental Loss Deductions. 03/29/2014

Gambling CPA Can't Deduct Share of Racetrack's Take Out Expenses. 03/28/2014

IRS Adopts Stricter Interpretation of One-Year Waiting Period for IRA Rollovers. 03/27/2014

Supreme Court Holds That Severance Payments Are FICA Wages. 03/27/2014

Budget Proposal Tries to Permanently Extend Research and Experimentation Tax Credit. 03/21/2014

IN-DEPTH: Tax Lien on Pension Plan Survives Bankruptcy Due to Ambiguity in Debtor's Petition. 03/13/2014

IRS Clarifies Requirements for Substantial Risk of Forfeiture in Final Regs. 03/12/2014

Millions Received from Qui Tam Award Is Ordinary Income. 03/09/2014

Court Agrees with IRS on Valuing Estate's Closely Held Stock Using NAV Method. 03/06/2014

Failure to Attach Required Documents Precludes Interest on Overpayment. 03/05/2014

Physician's Expenses Properly Treated as Miscellaneous Itemized Deductions on Schedule A. 03/03/2014

IRS Updates Procedure for Elections under New Capitalization Rules. 03/02/2014

IN-DEPTH: Home Builder Triumphs over IRS; Tax Court Allows Deferral of Millions. 02/28/2014

Complying with Court Order Wasn't Good Enough to Get Dependency Deduction. 02/27/2014

TRENDING: Final IRS Regs Delay Employer-Mandate for Some Medium-Sized Businesses. 02/2014

Form 1099 Questions on Tax Forms Continue to Plague Practitioners. 01/2014

IN-DEPTH: IRS Draft Instructions for Form 8960 Plays Down Gaps in NIIT Guidance. 01/2014

Grad School Deduction Disallowed Taxpayer Was Not Established in a Trade or Business. 01/2014

IN-DEPTH: IRA Withdrawals Pursuant to Forged Signatures by Wife Aren't Taxable to Husband. 01/2014

New Partnership Must Continue Amortizing Start-up Costs of Terminating Partnership. 12/2013

Top 15 Tax Developments of 2013. 12/2013

IN-DEPTH: Final Regs on .9% Additional Medicare Tax Address Repayment of Prior Year Wages. 12/06/2013

Proposed Regs Aim to Restrict Political Activities by Tax-Exempt Organizations. 12/05/2013

IN-DEPTH: 3.8% Net Investment Income Tax Regs Contain Substantial Changes. 12/04/2013

Final Regs on .9% Additional Medicare Tax Address Repayment of Prior Year Wages. 12/02/2013

Couple Escapes Penalty after Falsely Claiming Refundable Tax Credits and Rebates. 11/20/2013

District Court Allows Foreign Tax Credit in STARS Transaction. 11/19/2013

IRS Modifies FSA Rules to Allow Up to $500 to Be Used in Following Year. 11/17/2013

IRS Releases 2014 Inflation-Adjusted Amounts and Pension Colas. 11/12/2013

Use of Third-Party Contract Manufacturer Precludes Sec. 199 Deduction. 11/07/2013

IN-DEPTH: IRS Expands Guidance on Residential Energy Tax Credit. 11/06/2013

Exhaust Administrative Remedies Before Pursuing IRS for Violating Discharge Order 11/03/2013

Film Producer Can't Avoid $43 Million Restitution Order. 11/03/2013

IRS Announces 2014 Pension Plan Limitations 10/31/2013

Government Can't Hide Behind Code Sec. 6103 10/29/2013

Use of Wrong IRS Code Section Costs Taxpayer $100,000 10/28/2013

An In-Depth Look: Year-End 2013 Tax Planning for Businesses 10/25/2013

An In-Depth Look: Year-End 2013 Tax Planning for Individuals 10/25/2013

Sample Client Letter: Year-End 2013 Tax Planning for Businesses October 25, 2013

Sample Client Letter: Year-End 2013 Tax Planning for Individuals October 25, 2013

Taxpayer Didn't Meet Partial Payment Rule for Requesting Refund 10/2013

Drought-Stricken Farmers and Ranchers Have More Time to Replace Livestock 10/2013

2014 Tax Season to Start Later Following Government Shut Down 10/22/2013

Custom Homebuilder Must Capitalize Costs Incurred in Building Homes 10/20/2013

All Empowerment Zone Designations Terminate at End of 2013 10/20/2013

IRS Can't Be Compelled to Reopen OIC Returned Years Before CDP Hearing 10/18/2013

Couple Can't Discharge Tax Debt in Bankruptcy - Untimely Filings Were Not Returns 10/11/2013

Annual Per Diem Rate Guidance Changes "Incidental Expenses" Definition 10/11/2013

Court Denies Refund Claim for Payroll Service Company's Employment Taxes 10/2013

Fifth Circuit Partially Reverses Lower Court; Partners Entitled to Refund of Penalty Interest 10/2013

Baseball Player's Signing Bonus Must Be Amortized Over Life of Contract 10/10/2013

Tax Court Reverses Course on Gift Tax Issue 10/09/2013

IRS Issues Guidance on Effect of ACA on Certain Health Arrangements 10/05/2013

Closing Agreement Doesn't Preclude Reduction of Taxpayer's Dividends-Received Deduction 10/04/2013

IRS Required to Honor Designation of Employment Taxes. 10/04/2013

IRS Clarifies Rules for Qualified Real Property Expensed Under Section 179. 9/28/2013

An In-Depth Look: Final Capitalization Regs Contain Many Changes Favorable to Taxpayers. 9/25/2013

IRS Explains How to File DOMA-Related Employment Tax Refund Claims. 9/25/2013

S Corp Pass-Through Losses Disallowed; Lacked Sufficient Debt Basis. 9/22/2013

Sale of Tax Shelter Interests Were Income to S Corp's Sole Shareholder. 9/22/2013

Tax Attorney Should Have Known He Had No Basis for Losses. 9/22/2013

Purchasing Ex-Wife's Home Before Divorce Precluded First-Time Homebuyer Credit. 9/21/2013

Investor's Trading Activities Did Not Constitute a Trade or Business. 9/21/2013

Tax Research Methodology: A Practical Guide. Updated 9/19/2013

IRS Expands Situations in Which Innocent Spouse Relief Will Be Granted. 9/29/2013

Prop Regs Make Significant Changes to Rules on MACRS Property Dispositions. 9/28/2013

Proposed Section 174 Regs Would Broaden Definition of R&D. 9/15/2013

Estate's Attempt to Evade Code Sec. 642(g)'s Bar on Double Deductions Fails. 9/15/2013

IRS Final Capitalization Regs Contain Many Favorable Changes for Taxpayers. 9/13/2013

Many Opportunities Exist for Amended Returns: Same-Sex Marriages Recognized by IRS
for Federal Tax Purposes. 9/12/2013

IRS Final Regs Issued on Health Insurance Mandate Penalty for 2014. 9/11/2013

S Corporation Shareholder Retained Beneficial Ownership of Shares. 9/02/2013

A Practical Guide: Sustainable Research Tax Credit Claim. 9/01/2013

Proposed Regs Remove Two-Year Deadline for Filing for Innocent Spouse Relief. 8/29/2013

S Corp Procedure Expands Time for Applying Corrective Procedures to Late Elections. 8/29/2013

A Closer Look: Health Insurance Tax Credit for Small Business. 8/28/2013

Company's Dividend Deductions Did Not Meet All-Events Test; No Deduction Allowed. 8/23/2013

Failure to File Correct IRS Form Subjects Minister's Income to Self-Employment Tax. 8/23/2013

Consultant Not "Employer" With Respect to Work for Foreign Govt SEP Contributions Disallowed. 8/18/2013

IRS Penalties Disallowed as an Administrative Expense in Bankruptcy Case. 8/18/2013

Estate Loses $144,000 Refund After Failing to Properly Designate Payment as a Deposit. 8/15/2013

Final Meal and Entertainment Expense Regs Clarify Who Is Subject to the Limitations. 8/14/2013

Taxpayer with Zero Exclusion Ratio Is Fully Taxable on Pension Payments. 8/06/2013

Court Rejects Refund Claims from NOL Carryforwards Carrybacks. 8/06/2013

Real Estate Agent's Remax Fee Tax Deductible as Professional Expense. 8/05/2013

Certified Public Accountant (CPA) Can't Be Sued for Incorrect Form W-2. 8/05/2013

A Practical Guide to Perfecting Your Tax Research Techniques. 8/02/2013

Failure to Designate Parsonage Allowance Precludes Deduction; Penalties Upheld. 8/01/2013

IRS Expands Class of Taxpayers That Can Defer Advanced Payments for Gift Cards. 8/01/2013

IRS Won't Follow Tax Court Decision on Deductibility of Forbearance Payments. 7/31/2013

IRS Acquiescences to Expanded Review by Tax Court in Innocent Spouse Cases. 7/26/2013

IRS Postpones FATCA Implementation by Six Months. 7/26/2013

D.C. Circuit Court Affirms Denial of Tax-Exempt Status for Special Needs Trust. 7/22/2013

D.C. Circuit Reverses Tax Court Regarding Nonresident Alien Gambling Per-Bet Rule. 7/19/2013

No Home Office Deduction for Employee Working from Home for Her Own Convenience. 7/17/2013

New DOMA Update: An In-Depth Look at the Tax Implications of US v. Windsor. 7/05/2013

Generally, an IRA is Off Limits from Tax Collectors and Creditors in Bankruptcy. 7/05/2013

IRS Tries to Assess a Constructive Dividend on the Sole Shareholder of a Construction Company
in a Unique Way. 7/05/2013

Conservation Reserve Program Payments Subject to Self-Employment Tax. 7/05/2013

DOMA Struck Down - Opening the Floodgates for Amended Tax Returns. 6/26/2013

Individual Precluded From Contesting Trust Fund Recovery Penalty. 6/26/2013

Tax Treatment of Repair and Maintenance Expenditures. 6/26/2013

U.S. Employee Working Overseas Was Unable to Exclude Earnings from Income. 6/25/2013

Autistic and Bipolar Taxpayer Didn't Qualify as Financially Disabled. 6/25/2013

IRS Rules that Mexican Land Trusts Are Not Foreign Trusts. 6/19/2013

Taxpayer Denied Abandonment Loss for "Underwater" Home. 6/19/2013

Utilizing Preservation Tax Incentives to Reduce Property Owner’s Expenditures for Renovation. 6/12/2013

IRS Barred from Assessing Tax on Virgin Islands 1040s. 6/08/2013

Tax Evasion Sentence Upheld for Adult Entertainment Entrepreneur. 6/08/2013

Child Tax Credits Not Exempt from Missouri Bankruptcy Estate. 6/07/2013

Inappropriately Signed Return Keeps Statute of Limitations Open. 6/07/2013

Cooperative Must Separately Compute DPAD for Patronage and Nonpatronage Sourced Income. 6/05/2013

Debtor's QSub Status Is Not Property; Sole Shareholder Entitled to Revoke S Status. 6/05/2013

Does Issuance of Form 1099-C Dissolve Debt? Bankruptcy Court Parts Ways with Other Courts. 05/23/2013

Loan Guarantees to IRA-Owned Businesses Results in Loss of IRA Status. 05/23/2013

Ninth Circuit Holds that Surrender Value of Policies Can be Considered in Taxing Distributions. 05/14/2013

Courts Split on Tax Treatment of Gain on the Sale of Demutualized Stock 05/10/2013

Lack of Signed Release Costs Noncustodial Parent Dependency Exemption and Child Tax Credit 05/09/2013

Loving Case: Former IRS Commissioners File Amicus Brief Supporting IRS 04/27/2013

White House Releases Tax Proposals as Part of Fiscal Year 2014 Budget Plan 04/27/2013

Mechanics of Calculating Section 911 Housing Exclusion Explained By Chief Counsel's Office 04/23/2013

Taxpayers Did Not Make Reasonable Effort to Find Paying Renters - Rent Expenses Denied 04/22/2013

Estate's Reliance on Expert's Wrong Advice Was Reasonable Up to a Point 04/13/2013

Challenge to Circular 230's Limitation on Contingent Fee Arrangements Dismissed 04/12/2013

Taxpayer Can Deduct Unallocated Support Payments in Full as Alimony 03/27/2013

Fraudulent Amended Returns Filed by Company's Accountant Tolled Statute 03/17/2013

Obligation to Pay Delinquent Taxes Trumps Religious Obligations and College Expenses 03/14/2013

Step-by-Step Guide to Preparing a Return for a Disabled Veteran (Contributing Author: Kathryn Morgan) 03/14/2013

A Practical Guide: Sustainable Research Tax Credit Claim 03/05/2013

Charitable Deduction Allowed Despite Lack of Attached Qualified Appraisal 03/01/2013

Sequester Threatens IRS Taxpayer Services and Enforcement 02/28/2013

Proposed Regs Address Individual Health Insurance Mandate 02/25/2013

IRS Suffers Estate Tax Loss: An In-Depth Look at Estate of Kite v. Commissioner 02/18/2013

Court Rejects Attempt to Use QSub Election to Increase S Corp Stock Basis 02/14/2013

IRS Issues Annual Advice on Missing Form W-2's 02/14/2013

IRS Update: Ability to e-file Tax Returns Containing Form 4562 and/or Form 8863 02/08/2013

IRS Has Reopened Online PTIN System with Limitations 02/05/2013

Many 2012 Business Tax Filings Can Start on Monday February 4th, With Exceptions 02/02/2013

Loving v. IRS: District Court Slams IRS for Overreaching Its Authority 02/01/2013

Blank Spaces in Gift Documents Did Not Mean Decedent Retained Power to Alter Gifts 02/01/2013

IRS Releases New Tax Tables and Remaining Inflation Adjusted Amounts for 2013 01/19/2013

Tax Court Weighs In on Ex-Spouse Battles Over Dependency Exemption 01/06/2013

American Taxpayer Relief Act(ATRA)of 2012: An In-Depth Analysis 01/04/2013

Moonlighting Police Officer Was Independent Contractor Subject to Self-Employment Taxes. 01/01/2013

Failure to Get CPAs Advice on Conservation Easement Donation Leads to Penalties for Taxpayer 12/27/2012

A Practical Guide: Tax Treatment of Repairs and Maintenance Expenditures Under New Regs 12/21/2012

IRS Hints at Simplification of Temp Capitalization Regs; Delays Effective Date to 2014 12/19/2012

Proposed Regs Expand Guidance on Whistleblower Awards 12/19/2012

An In-Depth Look: The Additional .9% Medicare Tax 12/07/2012

An In-Depth Look: The 3.8% Net Investment Income Tax 12/06/2012

New 3.8 Percent Tax on Investment Income and .9 Percent Additional Medicare Tax 12/02/2012

New Capitalization Rules: Opportunities and Traps 11/26/2012

Tax Court Decides If Taxpayer's Coaching Business is a Hobby 11/24/2012

2013 Standard Mileage Rates Up 1 Cent per Mile for Business, Medical and Moving 11/21/2012

Court Sides with Taxpayer on Donation of Conservation Easement 11/21/2012

Bitter Feud Between Former CPA Partners Poses Unique Tax Issues 11/14/2012

Tax Planning in the Wake of "Status Quo" Election 11/09/2012

Self-Employment Tax Applies to LLC Member Guaranteed Payments, Tax Court Holds 11/09/2012

IRS Provides Tax Relief to Victims of Hurricane Sandy; Return Filing and Tax Payment Deadline Extended to Feb. 1, 2013 11/02/2012

IRS Releases Certain Inflation-Adjusted Figures for 2013; But Holds Off on Others 10/29/2012

PTIN Renewal Period Underway 10/28/2012

Timelines for Due Diligence and Other Requirements under FATCA 10/24/2012

S Corp Owner Liable for Tax on Entire Vested Accrued Benefit in ESOP 10/23/2012

Supreme Court Declines to Review S Corp Reasonable Compensation Case 10/22/2012

IRS Announces 2013 Pension Plan Limitations; Taxpayers May Contribute up to $17,500 to their 401(k) plans in 2013 10/18/2012

Proposed Regs Would Withdraw Onerous Covered Opinion Rules in Circular 230 10/1/2012

IRS Rejects Basis Harvesting by S Corp Shareholders Attempting to Recognize Built-in Losses 10/6/2012

Special Needs Trust Set Up by Elder Law Attorney Doesn't Qualify as an Exempt Organization 10/18/2012

Tax Court Rejects Attempt to Deduct Artificially Created $37 Million Loss; Penalties Upheld 09/20/2012

Failure to Identify Partners in Partnership Extends Statute, Tax Court Holds 09/19/2012

Failure to Bring Doctor's Note Precludes Finding of Financial Disability 09/15/2012

IRS Puts Employers on Notice Regarding Reimbursement Arrangements 09/13/2012

Court Rejects IRS Attempt to Use Obscure Provision to Deny Casualty Loss Deduction 08/30/2012

Payment of S Shareholders' Liability Wasn't Fraudulent Conveyance 08/17/2012

Proposed Regs Clarify Tax Treatment of Employer Reimbursement Arrangements 08/17/2012

Intermediate Transfer of Inherited IRA to the Taxpayer Is a Taxable Distribution 08/03/2012

Eight Circuit Sympathetic to Taxpayer's Arguments that Cattery Was a Trade or Business 08/03/2012

Ruling Discusses Whether Dividend Equivalents Affect $1 Million Compensation Cap. 07/15/2012

Taxpayer Can't Deduct Lodging and Meals During Transitional Period Relating to Job Change. 07/13/2012

No Deduction for House Donated to Fire Dept. 07/13/2012

IRS Issues New Guidance and Audit Procedures on FICA Taxes on Tips (Plus Client Letter) 07/06/2012

Supreme Court Upholds PPACA; Refresher on Healthcare Law's Tax Provisions 07/06/2012

Prop. Regs Aim to Clarify Requirements for Increasing S Shareholder Basis in Debt 06/25/2012

Temporary Regs Provide Guidance on EGT Portability Election 06/22/2012

Absent Congressional Action, Many Tax Provisions Are Due to Expire at the End of 2012 06/22/2012

Truck Driver Can Take Tax Deduction on Certain Unreimbursed Expenses, Including Clothing. 06/13/2012

Taxpayer Didn't Recognize COD Income on Subsequent Collection Attempts. 06/13/2012

IRS Prop. Regs Would Tighten Rules as to When a Substantial Risk of Forfeiture Exists. 06/10/2012

Increase in IRS Notices Leads to Loss in Productivity for Accountants. 06/10/2012

Trust Beneficiaries Not Liable for Estate Tax. 06/08/2012

Federal Circuit Invalidates Avoided Cost Rule Sec. 263A Reg. 06/08/2012


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