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A Primer on Employment Tax Withholding

When the IRS is involved, monetary transactions are never as simple as they appear on the surface. The late, great comedian Mitch Hedberg once told a story about being given a receipt after buying a doughnut. I bought a doughnut, and they gave me a receipt for the doughnut. I don’t need a receipt for the doughnut. I’ll just give you the money, and you give me the doughnut, end of transaction. We don’t need

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Effect of the Build Back Better Act on Corporate and Partnership Taxation

On September 15, the House Ways and Means Committee voted to approve sweeping changes to the Internal Revenue Code through the Build Back Better Act, which proposals, if ultimately passed, will have a significant effect on the taxation of corporations and partnerships. We discussed the changes proposed to affect estate and gift taxation in an earlier article. In this article we explore the effect of the Build Back Better Act on corporate and partnership taxation.

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Worker Classification: The Thin Line between Employees and Independent Contractors

Uncle Bill, Emu Farmer To discuss the thin line between employees and independent contractors, let’s imagine the following scenario—if you will indulge me. Your Uncle Bill operates a successful emu farm in southeastern Maine, so successful in fact that he finds himself unable to do the work on his own. (Uncle Bill no longer has your cousin Leroy to lean on, due to his most recent “run in” with the law involving a charge of

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Income Tax Issues
Tax Articles

Personal Liability under the At Risk Rules

So, you have a business loss.  Join the club.  The real question is whether you have personal liability under the at risk rules of IRC § 465. Personal Liability under the At Risk Rules of IRC § 465 For certain taxpayers (including individuals and certain closely held corporations), who are engaged in certain activities (including each activity engaged in by the taxpayer in carrying on a trade or business or for the production of income),

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Tax Articles

How to Implement the New Centralized Partnership Audit Regime of the BBA – Part Three

This post, entitled “How to Implement the New Centralized Partnership Audit Regime of the BBA,” is the third and final of a series on the new centralized audit regime that came into effect in 2018 under the Bipartisan Budget Act, replacing the old TEFRA procedures with new partnership-level adjustments.  The first article provided an overview of the primary differences between the BBA regime and that of the old TEFRA procedures.  The second article takes a

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Tax Articles

Understanding the New Centralized Partnership Audit Regime – Part One

This is the first of a series of three posts on the new centralized partnership audit regime that came into effect in 2018 under the Bipartisan Budget Act, replacing the old TEFRA procedures with new partnership-level adjustments.  This first article provides an overview of the primary differences between the BBA regime and that of the old TEFRA procedures.  The second article takes a deep dive into the Code and Treasury Regulations, explaining each new provision

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Tax Articles

The New Centralized Partnership Audit Regime – Part Two

This is the second of a series of three posts on the new centralized partnership audit regime that came into effect in 2018 under the Bipartisan Budget Act, replacing the old TEFRA procedures with new partnership-level adjustments.  The first article provided an overview of the primary differences between the BBA regime and that of the old TEFRA procedures.  This second article on the new centralized partnership audit regime takes a deep dive into the Code

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McCrory v. Commissioner (T.C. Memo. 2021-116)

On October 4, 2021, the Tax Court issued a Memorandum Opinion in the case of McCrory v. Commissioner (T.C. Memo. 2021-116). The primary issue presented in McCrory was whether the IRS Whistleblower Office’s rejections of the petitioner’s claims were unsupported by the administrative record and were arbitrary, capricious, an abuse

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Gregory v. Commissioner (T.C. Memo. 2021-115)

On September 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Gregory v. Commissioner (T.C. Memo. 2021-115). The primary issue presented in Gregory was whether the claimed deductions permitted under IRC § 183(b) for activities not engaged in for profit are not subject to the 2%

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A Primer on Employment Tax Withholding

When the IRS is involved, monetary transactions are never as simple as they appear on the surface. The late, great comedian Mitch Hedberg once told a story about being given a receipt after buying a doughnut. I bought a doughnut, and they gave me a receipt for the doughnut. I

Read More »

Clark v. Commissioner (T.C. Memo. 2021-114)

On September 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Clark v. Commissioner (T.C. Memo. 2021-114). The primary issue presented in Clark was whether the petitioner fraudulently underreported his income. Held:  Oh, dear God.  The fraud! The Tax Court’s Summary of the Issue in Clark

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Whistleblower 14377-16W v. Commissioner (T.C. Memo. 2021-113)

On September 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 14377-16W v. Commissioner (T.C. Memo. 2021-113). The primary issues presented in Whistleblower 14377-16W were whether the whistleblower could proceed anonymously, and whether the WBO abused its discretion in denying the whistleblower-petitioner an award. Held:

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Brown v. Commissioner (T.C. Memo. 2021-112)

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Brown v. Commissioner (T.C. Memo. 2021-112). The sole issue presented in Brown was whether the Tax Court has jurisdiction to order the refund of a TIPRA payment. What is a TIPRA Payment? The Tax Increase

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