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,…
Charitable remainder trust can be divided into separate trusts without adverse tax consequences Rev Rul 2008-41, 2008-30 IRB Mike Habib, EA In the context of two fairly detailed factual situations, a new revenue ruling makes it clear that a charitable remainder trust (CRT) can be divided into two or more…
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…
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…
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…
Final regs on dependent child of divorced or separated parents or parents who live apart T.D. 9408, 07/01/2008; Reg. § 1.152-4 Mike Habib, EA IRS has issued final regs on the rules for claiming a child as a dependent by parents who are divorced, legally separated under a decree of…
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…
New bill extends unemployment benefits for 13 weeks The President has signed into law H.R. 2642, “The Supplemental Appropriations Act of 2008.” Title IV of the bill authorizes an extension of unemployment insurance (UI) benefits. Individuals may be eligible for 13 weeks of extended benefits if they: (1) are fully…
House passes AMT relief with bipartisan majority – President threatens veto On June 25, the House by a vote of 233 to 189 approved H.R.6275, the “Alternative Minimum Tax Relief Act of 2008.” The bill will be sent to the Senate for consideration. The bill would patch the alternative minimum…
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…