As many of you know who follow my tax musings via this blog, I recently led a team of people that shepherded a Marijuana Dispensary through the IRS Examination and Appeals functions. The dispensary in question was owned and operated…
I was talking with a taxpayer the other day who registered as an LLC with Colorado Secretary of State. She developed an intriguing business model that is doing remarkably well according to the financial statement. As part of a tax…
According to IRC 357(a) if property transferred to a corporation in an IRC 351 nonrecognition transaction is subject to a liability, the assumption of that liability by the corporation generally is not treated as taxable "boot" for purposes of determining the amount…
The Internal Revenue Code is a complex beast. In the lunacy of it all I've been asked to define 'trafficking' as it relates to 26 USC § 280E - Expenditures in connection with the illegal sale of drugs which states as follows: "No…
As I understand the Cohan rule under the IRS' Guidelines For Determining Noncompliance, taxpayers are allowed a deduction for an estimated amount of expenses when it is clear the taxpayer is entitled to a deduction but is unable to establish the exact amount of…
Businesses that receive more than $10,000 in cash in one transaction (or several related transactions) must file IRS Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business. According to Program Manager Technical Advice (PMTA) 2010-012. Reg. §1.6050I-1(c)(1) and…
The purpose of this audit techniques guide (ATG) is to provide guidance for the examination of income in a cash intensive business. This guide can be used during all phases of the examination but is not all-inclusive The accurate reporting…
In a tax emergency, would you be ready? Well– good tax records not only help you prepare your tax return. They also help you answer questions if your return is selected for examination or prepare a response if you are…
IRS PTIN: P00605639
Enrolled Agent #: 85353
Email: john@johnrdundon.com
