Blog Archives

Protecting Americans from Tax Hikes (PATH) Act of 2015 – A Summary

Protecting Americans from Tax Hikes Act of 2015 (PATH) summarized by my friend Shirley Callahan EA. Some highlights include: Everyone will appreciate the permanency of the enhanced Educator Expenses, the Sales Tax deduction, and the R&D Credit. Section 179 is made

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Posted in DIY, Enrolled Agent, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, ITIN, Licensed Tax Professional, PATH Act 2015, Paying Taxes, Penalty, Tax Abuse, Tax Court, Tax Credit, Tax Fraud, Tax Guidance & Preparation, Tax planning, Tax Preparer, Tax Problems & Requests

U.S. Tax Court Settlements in IRS Appeals

U.S. Tax Court Settlements in IRS Appeals

Situations by which Docketed U.S. Tax Court Cases Settle in IRS Appeals

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Posted in Appeals & Audit Resolution, IRS Appeal, IRS Enforcement, Tax Court, Tax Relief, United States Treasury

More on Marijuana Taxation: Beck v. Commissioner & Accounting for Excise Tax Paid – CCM 201531016

Business Entity Selection and the Tax Consequences of Converting

UGH! I vowed to stop writing about the tax implications of marijuana cultivation and distribution. The catholic guilt of a dysfunctional adolescence must be burning deep today as resisting the urge to come back for yet another round of punishment

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Posted in Business Expense, Marijuana, Tax Court, Tax Deductible Expenses, Tax Guidance & Preparation

Coca Cola’s Recent IRS Statutory Notice of Deficiency – a Tipping Point in International Transfer Pricing Enforcement

In Coca Cola's SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when

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Posted in Foreign Income, Foreign Investment, International Tax, IRS Examination, Tax Abuse, Tax Court, Transfer pricing

Meal Expense – Navigating Between Internal Revenue Code Sections 162, 274, 132; IRS Technical Advice Memorandum 200030001; and, Churchill Downs v. Commissioner

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

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Posted in Business Expense, Deductible Expense, Disallowed Expenses, Employee Business Expense, Meal Expense, Tax Court, Tax Deductible Expenses, Taxable Income, Uncertain Tax Position

Richard S. Leyh et ux. v. Commissioner – Contemporaneous Log Detailing Rental Property Activity Permissible in Defining Real Estate Professional for Income Tax Purposes

Richard S. Leyh et ux. v. Commissioner (T.C. Summ. Op. 2015-27) details a case in which a taxpayer could revise her contemporaneous log of daily rental property activity and qualify as a real estate professional for income tax reporting purposes.

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Posted in Rental Real Estate, Tax Court, Tax Deductible Expenses, Tax Guidance & Preparation

Schumann v. IRS: Reg. 1.469-2(f)(6) – The Nuanced Relationship Between Passive Losses & Self Rental Gains

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

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

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Posted in 1031 Exchange, Appeals & Audit Resolution, Business Expense, Business Income, Deductible Expense, Disallowed Expenses, IRS Examination, Material Participation, Passive Activity, Rental Real Estate, Self Rental, Sub-chapter S, Tax Court, Tax Guidance & Preparation

Odujinrin v. IRS Commissioner Reinforces the Significance of Engaging a Reputable Enrolled Agent

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

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Posted in Back Taxes Owed, Business Expense, Disallowed Expenses, Employee Business Expense, IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, IRS Penalties, IRS Penalty and Interest Abatement, Tax Abuse, Tax Court, Tax Guidance & Preparation, Tax Preparer

US v. Clarke SCOTUS Decision Favors Taxpayers

The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that… “a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly

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Posted in IRS Audit, IRS Collections, IRS Enforcement, IRS Examination, IRS Penalties, IRS Penalty and Interest Abatement, Tax Abuse, Tax Court, Tax Deductible Expenses, Tax Guidance & Preparation, Tax Problems & Requests, Tax Relief

US v. Clarke SCOTUS Decision Favors Taxpayers

The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that... "a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly

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Posted in Audit Reconsideration, Business Expense, IRS Enforcement, IRS Examination, Tax Abuse, Tax Court, Tax Deductible Expenses, Tax Guidance & Preparation, Tax Preparer, Tax Problems & Requests, Tax Relief
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