Estate and Gift Taxation: The Basics (November 20, 2009)

Ed Zollars, CPA — Fri, 20 Nov 2009 08:00:12 +0000

The following are links related to Estate and Gift Taxation: The Basics presented in Des Moines for the Iowa Society of Certified Public Accountants on November 20:

Worker, Homeowner and Business Assistance Act of 2009 – new law
IRS Estate Tax Examinations - section of Internal Revenue Manual on Estate Tax Field Examinations
IRS Campus Estate Tax Procedures – section of Internal Revenue Manual dealing with Estate Tax returns on campus
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 of Keynote slides

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Partnership Taxation – Advanced Issues (November 18, 2009)

Ed Zollars, CPA — Wed, 18 Nov 2009 08:00:10 +0000

The following items were discussed in the Partnership Taxation Advanced Issues course presented for the Iowa Society of CPAs in Des Moines on November 18:

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
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Ed Zollars, CPA CPE Materials » Iowa Society of Certified Public Accountants

Estate and Gift Taxation: The Basics (November 20, 2009)

Partnership Taxation – Advanced Issues (November 18, 2009)