Google Profiles

A Google profile is simply how you present yourself on Google products to other Google users. It allows you to control how you appear on Google and tell others a bit more about who you are. With a Google profile, you can easily share your web content on one central location. You can include, for example, links to your blog, online photos, and other profiles such as Facebook, LinkedIn, and more. You have control over what others see. Your profile won’t display any private information unless you’ve explicitly added it.

You can also allow people to find you more easily by enabling your profile to be searched by your name. Simply set your existing profile to show your full name publicly.

Create your own profile

— J. Michael Stolp — My Info — See Disclaimer

IRS Grants Late §475(f) Election-But In a Very Unique Situation

The election to “mark to market” securities under §475(f) is an election that has very strict time limits imposed, pursuant to Revenue Procedure 99-17.

Many taxpayers have discovered to their dismay that this election is required to be made early in the year in which the method is to apply, and that the IRS will not waive allow a late election—generally because such an election clearly would be made with the benefit of hindsight. The Tax Court has numerous times backed the IRS up on this position for much the same reason—the position outlined in Revenue Procedure 99-17 is justified due to the obvious benefit a late electing taxpayer has from having better information than those that followed the rules.

FASB Reiterates FIN 48 for Private Entities This Year, Makes Minor Changes

The Financial Accounting Standards Board, in its July 8 Board Meeting, took action to confirm that it intends for private companies to comply with FIN 48 on income taxes this year, making some minor clarifying modifications for which it asked staff to draft an Accounting Standards Update that it plans to be effective for periods ending after September 15, 2009.

Official WordPress For BlackBerry App Now In Public Beta

Here is a nice tool for mobile web authors. It combines the best of WordPress with best of Blackberry.   Just as one trivial example, this article was found, edited, illustrated and posted from my BlackBerry, with a few clicks in a few minutes.

I’m bored. Being idle is mind numbing.

What I realized is that activity just for the sake of activity is wasteful and boring. It is almost like retirement.  What we do with our limited time and money maters.

Is this daily routine about right?

•           Wake up, breakfast and paper/news,

•           Workout,

•           Check email, job postings, apply to one or if a good day two,

•           Check out updates on LinkedIn, Facebook, etc.

•           Make a few calls,

•           Then nothing.

What is frustrating many of us is interviews are infrequent. Recruiters want to talk with us about nothing and our curiosity in glorified ‘working from home’ ads increase as time passes by.

Facebook cleans up its privacy controls

The social network will be transitioning users to the new settings soon through the use of an opt-in tool, as it works toward making more profile content public. It’s also doing away with regional networks, as expected.

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Posted by J. Michael Stolp from my Blackberry Storm.

Windows 7: Moving beyond Vista

Microsoft aims to make a much different first impression with Windows 7 than it did with Vista, its oft-maligned predecessor.

Read full article

Posted by J. Michael Stolp from my Blackberry Storm.

HOW TO: Use Social Media for Enterprise Business

HOW TO: Use Social Media for Enterprise Business

June 30th, 2009 | by Ben Parr

Companies such as Zappos, Dell, and JetBlue are all known as successes in harnessing the power of social media for business. However, the aforementioned businesses sell directly to consumers. How about the business that sells products to other businesses? What if you’re a company that builds inventory software or datacenters for the likes of Walmart? Is Twitter, Facebook (Facebook), Ning, or a company blog going to be any use?

In fact, the answer may surprise you. There are business-to-business companies that are utilizing the social web to find customers, to build up a reputation, and to get the upper hand on landing the big deal. There’s a great deal that social media offers to the non-consumer business. Here are four of the best ways to use social media when you’re in enterprise:

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— J. Michael Stolp — My Info — See Disclaimer

Despite 13 Months At Site and Living in Mom’s Home, Taxpayer Allowed Away From Home Costs

The question of what is a temporary assignment and whether the taxpayer was away from his tax home were the key issues in Senulis v. Commissioner, TC Summary Opinion 2009-97. Mr. Senulis undertook a project in an out of town location on a month to month basis. The technological feasibility of the project was in doubt, which accounted for the month to month agreement with the client. However, if it was feasible it was expected that the project would be completed in 9 to 10 months. Ultimately the project lasted for 13 months.

During this time period, Mr. Senulis, to reduce expenses, lived in a room with his mother in Texas. However, he continued to maintain a home with his significant other in Louisiana, paid many of the bills related to the townhouse there and intended to return to Louisiana once the project was finished.

Under §162(a) there is a limitation on away from home expense deductions—the Code holds that “the taxpayer shall not be treated as being temporarily away from home during any period of employment if such period exceeds 1 year.” Revenue Ruling 93-86 clarified the applicability of this provision if a taxpayer takes on employment away from his tax home for a period expected to be less than one year, but which after the fact is extended beyond one year. That ruling held that the taxpayer would be treated as away from home, and thus able to deduct expenses related to travel away from home, up until he became aware the employment would be expected to exceed the one year period.

The Tax Court held that Mr. Senulis was away from his tax home, finding that his tax home was not relocated to his mother’s home, as he continued to maintain what had clearly been his tax home prior to taking on this project and intended to return there once the project ended. As well, the court held that since unanticipated events led to the project being extended on a month to month basis eventually to 13 months, he was to be treated as away from home during the first 12 months of that period.

The Court went on to a detailed examination of the support for many of Mr. Senulis’s claimed expenses, matters we won’t detail at this time. However, somewhat amusingly, given the ruckus regarding the recent IRS announcements on cellular telephones, the Tax Court did disallow in the entirety his cellular telephone expense, noting that the law requires that documentation be kept in strict accordance with the requirements of the regulations under §274(d) to claim any deductions for cellular phones, since they are (at least for now) listed property under §280F(d)(4).

IRS Releases New Audit Technique Guide on Hobby Loss Issues

The IRS released an Audit Technique Guide on the Hobby Loss rules under Section 183. The guide, meant to instruct IRS examining agents on procedures to be used to determine if the limitations under §183 may be applicable to taxpayers they are examining, details that the provision applies not only to individuals, but also to partnerships and S corporations.

In its overview section, the guide quotes from a 2007 report of the Treasury Inspector General for Tax Administration that noted that, in reviewing returns of individuals that reported total income of over $100,000, it found over 1.5 million returns that reported Schedule Cs with losses for each of the four years from 2002-2005, suggesting that many of those individuals should have had their deductions limited under §183. The report went to note, rather ominously, that 73% of those returns were prepared with the assistance of paid preparers.

The obvious implication of that report is that a) the IRS should be more vigorous in examining these returns to disallow the claims of losses and b) the IRS should consider taking action against preparers who are signing off on returns containing such claims, such as through application of the §6694 penalties should the position be deemed not to have substantial authority and/or disciplinary action action against Circular 230 qualified preparers by the Office of Professional Responsibility.

All CPAs should be sure they are up to speed on the issues related to the hobby loss rules of Section 183, as well as considering procedures to insure that returns that have Schedule Cs that suffer continuing losses alongside sufficient other income to suggest the taxpayer may not have the proper profit objective are subject to special scrutiny to either advise the taxpayer that they are subject to the limits of §183 or to be sure the CPA’s files contain information that documents why, under the binding authorities that exist on this matter, the taxpayer either has substantial authority for not being subject to these limits or, if disclosure is made on Form 8275 and/or 8275-R (as appropriate) why there existed a reasonable basis for the position.

As well, the ATG may serve as a useful document to both distribute to all tax staff to let them know the IRS’s view of the matter (though always remembering that this is the IRS’s view, which may not always be the view the courts would take) as well as to hand to clients who often are more persuaded by an IRS document, as non-authoritative as we may know it is, than by all the stunningly brilliant research we may put forth them in a letter or memorandum.