Uncertain Tax Position Archives - John R. Dundon II, Enrolled Agent
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Uncertain Tax Position

05 May

Posted at 00:00h in Business Expense, Deductible Expense, Disallowed Expenses, Employee Business Expense, Meal Expense, Tax Court, Tax Deductible Expenses, Taxable Income, Uncertain Tax Position

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 incurred under IRC section 162...

10 Jun

Posted at 00:00h in Alter Ego, Sub-chapter S, Tax Abuse, Tax Deductible Expenses, Tax Fraud, Tax Guidance & Preparation, Tax Preparer, Tax Problems & Requests, Tax Relief, Trusts, Uncertain Tax Position, United States Treasury

What is an "alter ego" allegation? Aside of course being one of several nuanced yet distinct stages of intoxication, when it comes to the IRS it seems from my perspective that there are several elements of the alter ego doctrine that arose out of the California...

29 May

Posted at 00:00h in Asset Classification, Depreciation, Husband/Wife, Tax Guidance & Preparation, Tax Problems & Requests, Uncertain Tax Position

A certain important person in my reality - my wife - is becoming increasingly interested in the business end of biomass refineries. You go girl. Funny but this interest also happens to correlate with a new file I am developing involving a farmer who owns...

02 Mar

Posted at 00:00h in IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, IRS Transcript, ITIN, Tax Abuse, Tax Court, Tax Guidance & Preparation, Tax Problems & Requests, Tax Relief, Uncategorized, Uncertain Tax Position, United States Treasury

The best free US tax research sites in my opinion are: 1. For actually referencing the US Tax Code - Cornell University Law School as they seem to do the best job with updates and maintenance and at the end of the day the only thing...

07 Jun

Posted at 00:00h in 1031 Exchange, 1231 Exchange, Basis, Capital Gain, Capital Loss, Like/Kind Exchange, Sub-chapter S, Uncertain Tax Position

Check out the following 5 lessons I learned this week regarding IRC 351 nonrecognition transactions: 1. The basis assigned to stock received generally is the same as the basis in the property transferred to the corporation. If however you also receives boot from the corporation your...

04 Dec

Posted at 00:00h in Back Taxes Owed, Income, Intent To Levy, Intent To Lien, IRS Centralized Insolvency, IRS Collections, IRS Enforcement, IRS Levy, IRS Lien, Social Security, Social Security Tax, Tax Court, Uncertain Tax Position

The distinction of how this is possible distills down to understanding the nuanced difference between a 'Continuous' and a 'One Time' IRS tax levy. Under Code Sec. 6331(h) once a tax levy is approved, the effect of the levy on specified payments received by a taxpayer is...

25 Jun

Posted at 00:00h in Audit Technique Guide, Business Expense, Disallowed Expenses, Employment Tax, IRS Enforcement, IRS Examination, Payroll Tax Problems, Tax Guidance & Preparation, Tax Problems & Requests, Taxable Income, Uncertain Tax Position

According to IRS administrative guidelines to its examiners concerning Rev. Rul. 2012-18, published in the 2012-26 Internal Revenue Bulletin, when performing a tip examination (aka audit), IRS examiners must ensure that service fees or charges are properly characterized as wages and not tips. If the payment is...

16 Dec

Posted at 00:00h in Charitable Contribution, IRS Examination, Non-profit, Tax Guidance & Preparation, Tax Relief, Uncertain Tax Position

The IRS has released Form 8940, Request for Miscellaneous Determination that tax-exempt organizations will use to request certain determinations about their tax-exempt status.  In addition to foundation status issues, organizations will use this new form to obtain advance approval of certain activities and exemption from IRS Form 990 filing requirements. ...

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