TIGTA issues statutory review of IRS compliance with legal guidelines when issuing levies [ Audit Report No. 2008-30-097 ]: During the process of issuing levies, IRS has been complying with legal guidelines regarding proper notification and the protection of taxpayer rights, the Treasury Inspector General for Tax Administration (TIGTA) reported…
Houses passes legislation that would make sure certain government contractors pay employment taxes – Foreign shell companies payroll tax problems Mike Habib, EA myIRSTaxRelief.com The House of Representatives has passed legislation [H.R. 5719, Sec. 18, 4/15/08] proposed by Representatives Brad Ellsworth (D-Ind.) and Rahm Emanuel (D-Ill.) that seeks to end…
District court allows $60 million of income to be offset by Son-of-Boss shelter Sala v. U.S. (DC Co 4/22/08) 101 AFTR 2d ¶ 2008720 Mike Habib, EA myIRSTaxRelief.com A district court has allowed an individual to offset $60 million of compensation income with losses from a Son-of-Boss transaction. Facts. Carlos…
Payments made by retailer in connection with sales promotion weren’t taxable – PLR 200816027 Mike Habib, EA myIRSTaxRelief.com The IRS has privately ruled that payments made by a retailer in connection with a sales promotion were nontaxable purchase price adjustments and they weren’t subject to reporting or withholding. Facts. Taxpayer,…
Enhanced tax breaks make it an especially good time to buy business autos Mike Habib, EA myIRSTaxRelief.com Thanks to economic woes in general and financial trouble for auto manufacturers in particular, it’s a good time to shop for a new vehicle, if you can afford to do so. Thanks to…
Tax Court properly denied separate filer equitable innocent spouse relief – Christensen, (CA 9 4/21/2008) 101 AFTR 2d ¶ 2008-705 Mike Habib, EA MyIRSTaxRelief.com The Ninth Circuit has affirmed the Tax Court’s dismissal of a taxpayer’s claim for equitable innocent spouse relief under Code Sec. 6015(f). The Ninth Circuit agreed…
Qualified joint venture’s rental real estate income isn’t subject to self-employment tax – Chief Counsel Advice 200816030 Mike Habib, EA myIRSTaxRelief.com In Chief Counsel Advice (CCA), IRS has concluded that the qualified joint venture election under Code Sec. 761(f) doesn’t cause self-employment tax to be imposed on income from a…
TIGTA audit reviews effectiveness of IRS processing of Heavy Highway Vehicle Use Tax Return [Audit Report No. 2008-40-089]: The IRS should encourage more states to participate in its Alternative Proof of Payment Program for the collection of the Heavy Highway Vehicle Use Tax (also known as the Heavy Vehicle Use…
The IRS OKs deferral of income from intellectual property payments Mike Habib, EA myIRSTaxRelief.com The IRS has privately ruled that a taxpayer could defer reporting income from intellectual property payments until the tax year following the tax year of receipt of the payments under a revenue procedure governing advance payments.…
Grantor’s power to substitute trust property didn’t trigger inclusion in estate – Rev Rul 2008-22, 2008-16 IRB 796 Mike Habib, EA myIRSTaxRelief.com A new revenue ruling concludes that the corpus of an irrevocable trust that a grantor created during life is not includible in his gross estate under Code Sec.…