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.…
Offsets in Senate Finance’s farm bill include Schedule F loss limits, optional self-employment tax, and information reporting Mike Habib, EA MyIRSTaxRelief.com On April 18, the Senate Finance Committee conferees on the farm bill announced $2.4 billion of reforms/offsets – “double the reforms in the House or Senate bills alone” –…
IRS proposed regs would update federal tax lien priority provisions for holders of security interests Preamble to Prop Reg 04/16/2008, Prop Reg § 301.6323(b)-1, Prop Reg § 301.6323(c)-2, Prop Reg § 301.6323(f)-1, Prop Reg § 301.6323(g)-1 Mike Habib, EA myIRSTaxRelief.com IRS has issued proposed regs on the priority of federal…