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Tax Relief Blog

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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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Shareholder Constructive Distribution

Loan repayment to shareholder’s spouse wasn’t constructive distribution Beckley, 130 TC No. 18 (2008) Mike Habib, EA The Tax Court has ruled that payments made by a corporation to the wife of one of its shareholders represented repayment of money she advanced to a predecessor corporation. Despite the absence of…

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Employment / Payroll Tax Adjustments

Final regs include new process for reporting employment tax adjustments and refund claims T.D. 9405, 06/30/2008, Reg. § 31.6011(a)-1, Reg. § 31.6011(a)-4, Reg. § 31.6011(a)-5, Reg. § 31.6205-1, Reg. § 31.6302-1, Reg. § 31.6402(a)-1, Reg. § 31.6413(a)-1, Reg. § 31.6403(a)-2 Mike Habib, EA IRS has issued final regs on employment…

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