Taxpayers Not Allowed to Escape Tax or Late Filing Penalty by Arguing they Were Duped by a Charlatan Preparer

In Cunningham v. Commissioner, TC Memo 2009-194, the taxpayer, after ignoring the IRS regarding inquiries about his late filing of tax returns and the issues related to his claims for losses from horse related activities at the behest of the individual that prepared his return, decided to change course and at trial argued that he [...]

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Who uses suspense accounts effectively?

I see suspense accounts are still in use.  Why and are they effective?

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Taxpayer’s Need to Care for Ill Father Ruled a Valid Reason for IRS to Allow Late IRA Rollover

In Private Letter Ruling 200935047 the IRS allowed a late rollover by a taxpayer into her IRA account, ruling that her need to care for her ill father was a valid reason for allowing for a late IRA rollover.

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IRS Looks at Changing from LIFO Method for Lost Auto Franchise

In Chief Counsel Advice 200935024 the IRS took on a question that ties in to the recent shrinkage of dealerships by General Motors and Chrysler. The question that was posed to the Chief Counsel’s Office was whether a car dealer that either lost one of its franchises or even its only new car franchise could [...]

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With Taxpayer Assistance, IRS Finally Wins a Basis Shifting Partnership Six Year Statute Case

In a case where defeat was effectively snatched out of the jaws of victory, the way a transaction was reported on a return opened up the six year statute of limitations even though the actual transaction in question was not what the IRS planned to assess tax on. In the case of Highwood Partners v. [...]

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Free yourself and minimize duplication.

I am slightly embarrassed to say that I studied 5 investment statements of a new client for over 6 hours.  Before the 2nd hour was up I called Smith Barney to make sure I was reading them correctly.  I was also trying to understand the value of hours spent rekeying statement data into a spreadsheet.

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IRS Issues Guidance for Deferral of COD Income Under §108(i)

In Revenue Procedure 2009-37 the IRS gave guidance on the application of §108(i), added by American Recovery and Reinvestment Act of 2009, which provided for a deferral of recognition on gain from cancellation of indebtedness in certain situations. The new Revenue Procedure is the exclusive method for making an election to defer recognition of gain, [...]

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State Income Tax on Nontaxable Income Paid in Following Year Allocated Based on Prior Year

In Chief Counsel Email 200933026 the question at hand revolved around a taxpayer that paid state income taxes in the current year, but which partially related to income that was exempt from federal (but not state) income taxes in the prior year. Generally, pursuant to §265, when a taxpayer pays an otherwise deductible expense that [...]

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KIPLINGER – Good-bye, Laptop. Hello, Smart Phone.

Soon, your mobile wireless device will be able to do everything your laptop can do — maybe more.  http://www.kiplinger.com/businessresource/forecast/archive/smart_phones_as_laptops_090805.html   Posted by J. Michael Stolp from my Blackberry.

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Changes to Arizona’s Anti-Deficiency Law

I received the information copied below from Scott Stein, who is a real estate attorney I know and thought it was worth sharing. All of us have clients or know someone who has been affected by the current real estate crisis, and this is valuable information on changes in the law. Substantial changes to Arizona’s [...]

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