Category Archives: IRS

Swallows Holding Decision Now Available

Posted on February 19, 2008 by Russ

The Third Circuit Court of Appeals ruling in Swallows Holding, Ltd. v. Commissioner is now available online. The summary of the ruling is: “This case, grounded in the principles of administrative law, requires that we review the validity of an … Continue reading →

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Foreign Taxpayers Better File on Time…

Posted on February 18, 2008 by Russ

…or at least within 18 months of their due date. Why? IRS regulations hold that if a foreign corporation files after that date they cannot take any deductions. Consider a hypothetical corporation, Foreign Company Ltd., which has US source gross … Continue reading →

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One Last Electronic Filing Delay

Posted on February 17, 2008 by Russ

If you are going to file Form 982 you will not be able to electronically file until March 3rd. Form 982 is the new form that allows taxpayers to not have to claim canceled home mortgage debt as income. You … Continue reading →

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1031 Swaps for Vacation Homes

Posted on February 17, 2008 by Russ

The IRS gave the go-ahead to §1031 exchanges for vacation homes. Do note there are significant restrictions. If you own a second home and are considering a §1031 exchange, make sure you follow the restrictions. Joe Kristan has the details … Continue reading →

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Taxing the Virtual World

Posted on February 14, 2008 by Russ

Let’s suppose you’re playing an online role playing game such as Second Life. You’ve accumulated quite a bit of virtual property, and have a stash of virtual money. James Doe offers you $5,000 for your virtual money and virtual property—that’s … Continue reading →

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Strawberry Settles

Posted on February 13, 2008 by Russ

Darryl Strawberry, the former major league baseball player, has been in lots of trouble over his life. He’s battled drugs, cancer, ex-wives, and baseball players. Today he agreed to settle a tax dispute with the IRS. Back in 1995 Darryl … Continue reading →

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The New Standard for Preparers

Posted on February 10, 2008 by Russ

In years past, if I took a position on a tax return it needed “Substantial authority.” That’s equivalent to about a 30% chance of being upheld. Congress changed the law; now in order for me to take a position it … Continue reading →

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If You Lose, Try 66 More Times….

Posted on February 6, 2008 by Russ

There are losing streaks and then there are really long losing streaks. Larry Harvey has not had a good year battling IRS attorney Randall Preheim. Yesterday, as Joe Kristan noted, Mr. Harvey lost his 64th and 65th cases. Today, that … Continue reading →

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Final Thoughts on the Snipes Trial

Posted on February 3, 2008 by Russ

Why was Wesley Snipes found not guilty of tax fraud charges? Was it a repeat of the OJ Simpson case? Is this a huge victory for tax protesters? It’s interesting that both prosecutors and defense attorneys praised the jury in … Continue reading →

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Is the IRS Reading Taxable Talk?

Posted on January 28, 2008 by Russ

It’s not a dumb question. The TaxProf Blog quotes a piece in Tax Analysts that states that the IRS is aware of tax blogs. “The tax press has played an increasingly important role in the IRS’s communications strategy as the … Continue reading →

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