Category Archives: Tax Reporting

IRS Finalizes Regs Removing Requirement To File Code Sec. 83(b) Election With Return

Final regs have been issued that remove the requirement that a taxpayer making a Code Sec. 83(b) election file a copy of the election with the taxpayer’s return for the year of the Code Sec. 83 transfer. The final regs track proposed regs issued … Continue reading

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Offshore Trusts Were Used To Commit Tax Fraud, Bankruptcy Court Finds

A federal bankruptcy court has found that a taxpayer used offshore trusts to hide some $1 billion from U.S. taxation. The court was not persuaded that the taxpayer had used the offshore trusts for tax deferral, as he claimed, rather … Continue reading

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IRS Announces Acquiescence In Per Taxpayer Mortgage Deduction Ruling

The Ninth Circuit Court of Appeals, reversing the Tax Court, had found that when multiple unmarried taxpayers co-own a qualifying residence, the debt limit provisions apply per taxpayer and not per residence.

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Taxpayer Not Required To File FBAR For Offshore Online Gambling Accounts; Accounts Were Not Banks

The Ninth Circuit Court of Appeals has held that a taxpayer was not required to file a Foreign Bank and Financial Account Report (FBAR) with respect to two online gambling accounts established in foreign countries used only to play poker … Continue reading

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Tax Court Denies Conservation Deduction; Easement Not Protected In Perpetuity

With the increased popularity and scrutiny of Conservation Easements, we thought it would be of interest to outline a recent tax court decision.  In a case of first impression, the Tax Court has found that a conservation agreement violated the … Continue reading

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Partners Who Work For Disregarded Entity Owned By Partnership Are Self-Employed

Partners Who Work For Disregarded Entity Owned By Partnership Are Self-Employed The IRS has issued final, temporary and proposed regs that preserve a partner’s status as a partner, and not an employee, where the partner works for a disregarded entity … Continue reading

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Proposed Regs Clarify Reporting Of Educational Expenses On Form 1098-T

The IRS has issued proposed regs that provide detailed guidance to higher education institutions on how to report tuition and other qualified expenses on Form 1098-T, Tuition Statement. The proposed regs also provide penalty relief for the institution’s failure to … Continue reading

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Ninth Circuit Allows Home Developer’s Use Of Completed Contract Method For Entire Development

Affirming the Tax Court, the Court of Appeals for the Ninth Circuit has found that a residential home developer properly used the completed contract method (CCM) of accounting for the entire development, not just individual houses. The taxpayer’s method of … Continue reading

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Tax Court Ruling on Activity Qualified As Business, Not Hobby

Tax Court Ruling on Activity Qualified As Business, Not Hobby In TC Memo 2016-71, the Tax Court found that a taxpayer’s hair-braiding             activity qualified as a business, where the taxpayer had a genuine, if optimistic, … Continue reading

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Rental Losses Not Automatically Nonpassive Due To Status As Real Estate Professional

The Court of Appeals for the Ninth Circuit has found that a taxpayer’s rental losses were not automatically nonpassive because of her status as a real estate professional. The court rejected the taxpayer’s argument that she did not need to … Continue reading

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