The IRS on Thursday issued Notice 2009-82 to provide relief for taxpayers who have received required minimum distributions in 2009 from an IRA or similar account. Such taxpayers have until Nov. 30, 2009, (or within 60 days of the distribution, whichever is later) to roll over the distribution into another
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Offshore Account Voluntary Disclosure Deadline Extended to Oct. 15
The IRS today extended the deadline for voluntary disclosures by taxpayers with unreported income from hidden offshore accounts from this Wednesday, Sept. 23, to Oct. 15. The IRS cautioned that there would be no further extensions. The IRS said that tax practitioners had requested an extension because some are having
IRS Finalizes Rules on COD Reporting
The IRS on Thursday issued final regulations regarding information returns for cancellation of indebtedness by certain entities (T.D. 9461). The regulations are designed to avoid premature reporting by certain entities that are currently required to file information returns and to reduce the number of returns required to be filed. They
IRS Expands, Updates Appeals Mediation Process
The IRS on Friday expanded the number of cases that are eligible to go through mediation in Appeals and updated the mediation procedures (Revenue Procedure 2009-44). The IRS’ Appeals mediation program was authorized in 1998. The IRS Appeals function is designed to resolve tax controversies without litigation. The mediation program
IRS Boosts Tax Incentives for Retirement Savings
The IRS released several pieces of guidance Tuesday designed to boost tax incentives for retirement savings. The initiatives include expanded opportunities for automatic enrollment in 401(k) plans, vehicles for taxpayers to save their tax refunds and convert accrued vacation time into savings, and better explanations of the available options for
IRS Provides Guidance on Late Entity Classification Elections
The IRS on Thursday released Revenue Procedure 2009-41, giving eligible entities guidance on how to obtain relief when they make a late entity classification election. The relief is available for three years and 75 days after the requested effective date of the eligible entity’s classification election. Under the check-the-box regulations,
Broken Home: Divorce and the Principal Residence
When Bill and Jen decided to divorce, they never expected their personal residence to become a major problem. Initially, Jen thought she wanted to stay in the house. She was emotionally attached to the home, and she thought remaining in it would help minimize the impact of the divorce on
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TIGTA: CLEARER 1040 COULD REDUCE TAXPAYER ERRORS A few relatively minor changes to Form 1040 could yield improvements in preventing common taxpayer errors, the Treasury Inspector General for Tax Administration (TIGTA) said in an audit (available at tinyurl.com/m8625m). Analyzing the approximately 7 million math error notices the IRS sends annually,
Ninth, Federal Circuits: Basis Overstatement Not Income Omission
An overstatement of basis does not constitute a substantial omission of gross income that would extend the deficiency statute of limitations to six years, the Ninth Circuit Court of Appeals ruled, upholding the Tax Court. The decision in Bakersfield Energy Partners v. Commissioner puts the Ninth Circuit in line with
Gifting Shares of Stock in a Closely Held Business
With the current economic downturn causing dislocations and struggles for businesses of all sizes, family-owned businesses may find their values diminished along with their immediate prospects. But with these challenges come opportunities for succession planning. Because closely held businesses may now be worth less than formerly, this might be a
Trusts as S Corporation Shareholders
Sometimes a C corporation considering S corporation status has a trust as a shareholder. If the trust was not originally drafted with the intent of being an eligible S corporation shareholder but continues to hold the stock, the corporation could be prevented from making the S election. Nevertheless, it may
No Penalty Tax on Additional IRA Distributions
The Tax Court ruled that paying higher education expenses from an IRA was not a modification of a taxpayer’s annuity payments from the IRA that would have made the payments subject to the 10% additional tax on early distributions. Generally under IRC § 72(t), distributions received from an IRA before
Loan Refinancing Deemed a Taxable Distribution
The Tax Court found that the amount by which a taxpayer’s refinancing of a loan from his qualified retirement plan exceeded statutory limits was a deemed distribution subject to the 10% additional tax. Under section 72(p)(2), a loan from a qualified retirement plan to a participant is not treated as
Full-Time Medical Residents Not Exempt From FICA
Several circuits have ruled on whether medical residents are eligible for the student exception to FICA (see “Tax Matters: FICA for Medical Residents Splits Circuits,” JofA, Jan. 08, page 73). Until recently, the issue had been whether a medical resident could be considered a “student” and a hospital could be
The Readable Code and Regs: Partnerships, 2009 Edition
edited by Glenn L. Madere, J.D., LL.M. Readable Press, 2009, 1,078 pp. (vol. 1) and 1,382 pp. (vol. 2) Every neophyte in tax practice has no doubt wondered why someone couldn’t publish a plain-language gloss of the Internal Revenue Code and associated regulations. Let’s face it: Tax statutes and
Courts Split on Tax Shelter Exception to Practitioner Privilege
In the long-running Countryside Limited Partnership case, the Tax Court ruled against a government documents discovery request, saying the government had not met its burden of proof for showing the documents were in connection with the promotion of a tax shelter. Thus the government was unable to overcome the federally
AICPA Calls for Civil Tax Penalty Reform
The AICPA called on Congress and the IRS and Treasury Department to reform civil tax penalties, which it said have strayed from their intended purpose of promoting voluntary compliance with tax laws. A report and cover letter signed by Alan Einhorn, chair of the AICPA’s Tax Executive Committee, were submitted
IRS Modifies Automatic Accounting Method Change Procedures
The IRS on Thursday modified the procedures for obtaining automatic consent to change an accounting method. Revenue Procedure 2009-39 amplifies, modifies and clarifies various earlier pieces of guidance that had established the general procedures for taxpayers to secure advance IRS consent to an accounting method change. Last year, the IRS
Taxpayer Wins Lawsuit on Valuing Transfers of LLC Interests
In a case involving the proper valuation of LLC interests that were transferred by a taxpayer into trusts set up for the benefit of her children, the Tax Court has held that transfers should be valued as transfers of LLC interests and not, as the IRS had argued, as transfers
IRS Provides Guidance on Election to Defer COD Income
In Revenue Procedure 2009-37, the IRS has provided guidance to taxpayers on how to make the new election to defer recognizing cancellation of debt (COD) income under IRC § 108(i). The revenue procedure also requires taxpayers who make the election annually to provide additional information on their returns, starting with
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