01.06.11

Current Federal Tax Developments (January 6, 2011)

Posted in California at 1:00 am by Ed Zollars, CPA

Below are items discussed in the Current Federal Developments course given on January 6, 2011 in San Mateo, CA:

• Findlaw Cases & Code – Links to Findlaw resources for US Code, Regulations & Court Cases.  Court pages contain option to sign up for email of new cases released each day.
• US Tax Court – Ruling posted Monday-Thursday at 1:30 pm Mountain time.
• IRS Rulings – “Drop” site for Revenue Rulings, Revenue Procedures, Notices and the like
• IRS Written Advice - Location for IRS postings on private letter rulings, technical advice memoranda, Chief Counsel Advice and similar “nonbinding” guidance that is issued by the IRS Chief Counsel’s office
• Recent Updates – developments since the manual was printed last week

Permalink Comments

01.24.10

Partnership Taxation – January 24, 2010

Posted in California at 1:00 am by Ed Zollars, CPA

The following items were discussed in the Partnership Taxation Advanced Issues course presented January 24, 2010:

• 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

Below is a Google Voice connect box. You can click on the button, provide your phone number, and Google will connect us toll free by calling you back and then, when you answer, calling me. The call is forwarded to me wherever I might be at the time. If I’m not available, you can leave a voice mail.

Permalink Comments