Schumann v. IRS: Reg. 1.469-2(f)(6) - The Nuanced Relationship Between Passive Losses & Self Rental Gains. Back to my friends that I previously wrote about who misunderstood passive activity and material participation. They are a married couple filing jointly and own a very successful business together structured...
Defining Passive Activity Between Spouses - Beyond the Bedroom: What Is Material Participation? Ha! One would imagine this is the script to a low budget B-rated film by the title, it is not. But if it got you reading all the better because you may want...
Once again another year is almost behind us and right after the new year income taxes are coming. The forthcoming tax environment is extraordinarily unusual and can subsequently be very scary. Basically what you need to know is that ALL Americans will be seeing changes on...
What I love most about Colorado, more than the 300+ days of sun every year and the glorious rocky mountains, are the people. Â For the most Coloradans are risk taking job creators, starting new businesses from scratch out of their garages and turning passions for...
In Wole Odujinrin v. IRS Commissioner the petitioner, a hematology oncologist who represented himself, did not have adequate substantiation to support his petition and was not entitled to claim a net operating loss. He was also liable for an accuracy-related penalty under IRC 6662 - the expensive...
How to Calculate Basis of a Primary Residence Converted to Rental Property [Reg. §1.168(i)-4(b)] [Reg. §1.165-9(b)(2)] can be a nuanced and complicated question to answer as it depends on a handful of specific facts and circumstances. Many people have built impressive residential real estate portfolios...
Worker Classification & the Colorado Department of Labor & Employment This post is about my experiences as they pertain to the Colorado Employment Security Act of 2013. First off let me start by saying that there are some really good hard working bureaucrats paid by our tax...
I was brought in on another interesting file this week involving a US Citizen seeking expatriation that I was strongly advised to run away from by my mentors and friends simply because it is easy to paint a picture of these types of folks as having...
There are a LOT of people from Canada in Denver, Colorado where I spend the majority of my time as a student of the US tax code. Â Many dual citizens got stung by the reasonably new US FBAR tax laws and there were some tragic...
What is an FTE? What is a Seasonal Employee?...