Back in June 2014 I blogged about the new IRS Regulations governing tangible personal property. These regulations prompted a vigorous debate over the last 7 months between the most astute students of the US Tax Code as to what constitutes…
This blog is my personal tax research tool. Pursuant to the rules of professional conduct set forth in US Treasury Circular 230 nothing contained in this blog was intended to be used by any taxpayer for the purpose of avoiding penalties that…
If you are in the business of dispensing marijuana according to the United States Office of Homeland Security you are selling an illegal drug not a medicine like many individual states believe. Nevertheless Internal Revenue Code IRC 280(E) states that the expenses…
From a tax perspective the fundamental issue is whether a legitimate business purpose exists for the formation of a distinct entity to do a sale leaseback. If one exists and this is pursued all elements of the transaction should meet…
Unless of course you are married and filing a joint tax return, whereby the IRS essentially classifies both individuals together as a single tax payer, you should take care to allocate costs equitably for items of shared ownership. In US…
Okay this is pretty huge in regards to some of the IRS Examination Appeals work I have been doing lately. The bottom line is that you need to follow the asset classification rules if you are going to engage in…
For income tax depreciation purposes there are two major types of assets: Sec. 1250 real property and Sec. 1245 personal property. When owners acquire commercial property or tenants invest in leasehold improvements, many only allocate the purchase price between land…
As part of the IRS's continuing efforts to require greater disclosure of tax positions and strategies on returns, it recently released new, mandatory disclosure rules for grouping passive activities. Rev. Proc. 2010-13 for the first time mandates that passive-activity groupings…
On October 3, 2008, President George W. Bush signed the Emergency Economic Stabilization Act of 2008. Tucked away in the Act is a provision that moves the responsibility of basis determination from the shoulders of the taxpayer to the shoulders of…
IRS PTIN: P00605639
Enrolled Agent #: 85353
Email: john@johnrdundon.com
