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Tax Relief Blog

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Private Trust Companies

Proposed revenue ruling gives green light to use of private trust companies Notice 2008-63, 2008-31 IRB Mike Habib, EA A new notice contains a proposed revenue ruling that would allow families to use private trust companies (PTCs) in their estate planning without adverse income, estate, gift or generation-skipping transfer (GST)…

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Taxpayer Advocate Annual Report

National Taxpayer Advocate annual report to Congress identifies priorities and issues for upcoming year [IR 2008-87]: An annual report on the priority challenges and issues facing the Office of the Taxpayer Advocate (OTA) was delivered to Congress on July 8. The report, National Taxpayer Advocate’s 2009 Objectives Report to Congress,…

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Cell Phone Deductibility

IRS discusses easing of cell phone recordkeeping requirements [Information Letter 2008-0012]: The IRS has issued an information letter in response to a question regarding the noted difficultly that states and localities are having drafting cell phone policies that comply with IRS recordkeeping requirements. Under IRC §162(a), individuals may take deductions…

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LP Limited Partner Deductions

Limited partner’s investment interest from trader partnership deductible above-the-line Rev Rul 2008-38, 2008-31 IRB; Ann. 2008-65, 2008-31 IRB Mike Habib, EA Earlier this year, IRS issued Rev Rul 2008-12, 2008-10 IRB 520 concluding that where a non-corporate limited partner doesn’t materially participate in the partnership’s activity, his distributive share of…

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Opportunity Letter – Offshore Account

Judge: IRS can seek tax information from Swiss banking giant UBS in expanding investigation Associated Press WorldStream via NewsEdge : MIAMI_A federal judge agreed Tuesday to allow the IRS to serve legal papers on Swiss banking giant UBS AG in an expanding investigation into U.S. taxpayers who may have used…

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Property Seizure Compliance

TIGTA results of 2008 review IRS compliance with legal guidelines when conducting property seizures [Audit Report No. 2008-30-126]: IRS has usually followed the numerous legal and internal guidelines that apply to seizures of taxpayers’ property, the Treasury Inspector General for Tax Administration (TIGTA) said in a recent audit. TIGTA based…

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