Taxpayer who had filed tax returns with the U.S. VIBIR was a bona fide resident of the U.S. Virgin Islands, and the statute of limitation on assessment had expired on the U.S. returns.
Personal Goodwill: Alive and Well Indeed!
Recent Tax Court decisions illustrate that with the right facts, the sale of personal goodwill, as an asset separate from corporate-owned goodwill, should withstand challenge.
Strategies for Minimizing the Impact of Income in Respect of a Decedent
This item discusses issues created by income in respect of a decedent and presents strategies and planning insights to assist taxpayers and their tax advisers with minimizing its impact.
Volunteering at Low Income Taxpayer Clinics Can Provide CPAs Valuable Experience
Volunteering for a Low Income Taxpayer Clinics pro bono panel gives a CPA a chance to provide valuable community service outside busy season and obtain additional experience in tax representation.
What Taxpayers Need to Know to Comply With the Final Tangible Property Regulations
An overview of the final tangible property regulations and discussion of the procedural guidance and what taxpayers will need to consider in complying with the final regulations.
Selling Partnerships That Own CFCs: A Potential Trap for the Unwary
Should gain recognized on a sale of a partnership that owns CFC stock be treated as capital gain or ordinary income?
Why the Internal Revenue Manual Is Valuable to Your Clients
Understanding how IRS personnel are instructed to perform certain procedures can be valuable to practitioners. This item contains several key areas of the IRM that should be noted in tax practice.
Wife of Anti-Tax Author Sentenced to Prison
A taxpayer was sentenced to 18 months in prison followed by one year of supervised release after being convicted of criminal contempt for failing to file amended tax returns as ordered by a judge and for filing a false income tax return.
Understanding IRS Form 1099-K Letters and How to Quickly Respond
Taxpayers that sell products or services online or accept payment cards for sales need to be aware of IRS notice letters relating to Form 1099-K.
New Procedures Designed to Restore Confidence in Appeals’ Independence, Improve Efficiency
New provisions of the Internal Revenue Manual affect not only IRS Office of Appeals procedures, but also how Examination develops its cases and how taxpayers access Appeals.