12.18.09
Partnership Taxation – Advanced Issues (December 18, 2009, Pendleton, Oregon)
The following items were discussed in the Partnership Taxation Advanced Issues course presented for the Iowa Society of CPAs in Pendleton, Oregon on December 18:
- Late Year Summary of Developments – Information on developments related to partnerships from the latter portion of 2009
- Partnership – Audit Technique Guide – IRS guide last revised in August 2008
- Worker, Homeowner and Business Assistance Act of 2009 – new law
- FTB Position on TIC and Revenue Proc 2002-22 – FTB considers qualification under Revenue Procedure 2002-22 a minimum, but not necessarily in its self-sufficient, to qualify as an exchange of other than a partnership interest.
- Norwood v. Commissioner, TC Memo 2000-84
- Garnett v. Commissioner, 132 TC No. 19, LLC members aren’t automatically passive (LLC member not the same as limited partner)
- Revised Procedure for Late Entity Selection – revised manual pages on new late election Revenue Procedure effective September 28, 2009.
- Article on Partnerships and §6501(e) Six Year Statute – article I wrote for the Arizona Society of CPAs blog site.
- IRS FAQ on Unified Partnership Audits – Chief Counsel Notice issued August 21, 2009
- Suzanne J. Pierre v. Commissioner– Check the box does not apply to single member LLC for gift tax valuation
- Malkin v. Commissioner – Taxpayer blows transfer tax planning due to both implied retained life estate and indirect gift on formation problems, among others.
- Presentation Slides – PDF format file
- My Twitter Feed – my Twitter name is edzollars
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