Presentation is loading. Please wait.

Presentation is loading. Please wait.

2012 IRS Tax Updates and Current Developments. Presented by … Raul O. Serrano, Jr. C.P.A. www.SerranoCPA.net.

Similar presentations


Presentation on theme: "2012 IRS Tax Updates and Current Developments. Presented by … Raul O. Serrano, Jr. C.P.A. www.SerranoCPA.net."— Presentation transcript:

1 2012 IRS Tax Updates and Current Developments. Presented by … Raul O. Serrano, Jr. C.P.A.

2 Congress at the 13 th hour, preserved most of the George W. Bush-era cuts and extended many other lapsed provisions. The American Taxpayer Relief Act, H.R. 8

3 Income Tax Rates: Individual Changes: Income Tax Rates: 10%, 15%, 25%, 28%, 33%, and 35%). A new rate of 39.6% is imposed on taxable income over $400,000 for single filers, $425,000 for head of household filers, and $450,000 for married taxpayers filing jointly. All of the individual marginal rates under Economic Growth & tax Relief Reconciliation Act of 2001 (EGTRRA) & Jobs and growth tax relief reconciliation act of 2003 (JGTRRA) were retained. 10%, 15%, 25%, 28%, 33%, and 35%). A new rate of 39.6% is imposed on taxable income over $400,000 for single filers, $425,000 for head of household filers, and $450,000 for married taxpayers filing jointly. ($225,000 for each married spouse filing separately).

4 Phase-out of itemized deductions & personal exemptions: Individual Changes: Phase-out of itemized deductions & personal exemptions: phase-out is reinstated at a higher threshold of $250,000 for single taxpayers, $275,000 for head of household, & $300,000 for married taxpayers filing jointly. The personal exemptions and itemized deductions phase-out is reinstated at a higher threshold of $250,000 for single taxpayers, $275,000 for head of household, & $300,000 for married taxpayers filing jointly.

5 Capital Gains & Dividends Individual Changes: Capital Gains & Dividends 20% individuals above the top income tax bracket threshold15% middle bracketszero rate for taxpayers in the 10% and 15% brackets A 20% rate applies to capital gains and dividends for individuals above the top income tax bracket threshold; the 15% rate is retained for taxpayers in the middle brackets. The zero rate is retained for taxpayers in the 10% and 15% brackets.

6 Alternative Minimum Tax Individual Changes: Alternative Minimum Tax is permanently indexed for inflation2012 $78,750 for married taxpayers filing jointly and $50,000 for single filers The exemption amount for the AMT on individuals is permanently indexed for inflation. For 2012, the exemption amounts are $78,750 for married taxpayers filing jointly and $50,000 for single filers. Relief from nonrefundable credits is retained.

7 Estates & Gift Tax Individual Changes: Estates & Gift Tax retained at $5 million indexed for inflation top tax rate increases from 35% to 40% effective January 1, 2013 The estate & gift tax exclusion is retained at $5 million indexed for inflation (5.12 million for 2012), but the top tax rate increases from 35% to 40% effective January 1, The estate tax “portability” election, under which, if an election is made, the surviving spouse’s exemption amount is increased by the deceased spouse’s unused amount, was made permanent by the act.

8 Not Extended Individual Changes: Not Extended was not extended & has reverted to 6.2%. Among the tax items not addressed by the act was the temporary lower 4.2% rate for employees’ portion of the Social Security payroll tax, which was not extended & has reverted to 6.2%.

9 New Taxes

10 3.8 % Medicare Contribution Tax “unearned income Medicare contribution” taxes on higher- income individuals, estate and trusts. Taking effect immediately on January 1, 2013 The Medicare surtax will be imposed on the taxpayer’s “net investment income” (NII) and will generally apply to passive income. The Medicare surtax will also apply to capital gains from the disposition of property.

11 3.8 % Medicare Contribution Tax “unearned income Medicare contribution” taxes on higher- income individuals, estate and trusts. The Medicare tax will not apply to: Income derived from trade or business Sale of property used in a trade or business The Medicare surtax will apply to the lesser of the taxpayer’s NII or the amount of “modified” adjusted gross income above a specified threshold.

12 3.8 % Medicare Contribution Tax “unearned income Medicare contribution” taxes on higher- income individuals, estate and trusts. Specified Thresholds: $250,000 for married taxpayers filing jointly or a surviving spouse; $125,000 for married taxpayers filing separately; and $200,000 for single and head of household taxpayers.

13 What is included in Net Investment Income? Interest Dividends Capital gains Rental and royalty income Non-qualified annuities, Business that are passive activities to the taxpayer( within the meaning of IRC section 469)

14 To calculate your NII, your investment income is reduced by certain expenses … Such as: Investment interest expense Investment advisory and brokerage fees Expenses related to rental and royalty income And, state and local income taxes properly allocable to items included in Net Investment Income.

15 What are some common types of income that are not Net Investment Income? Wages Unemployment compensation Operating income from a nonpassive business Social security benefits Alimony Tax exempt interest Self-employment income Alaska permanent fund dividends Distributions from certain qualified plans.

16 QUESTION: Will I have to pay both the 3.8% NIIT and the additional.9% Medicare tax? You may be subject to both taxes, but not on the same type of income. The.9% additional Medicare tax applies to individuals’ wages, compensation and self- employment income over certain thresholds, but it does not apply to income items included in Net Investment income.

17 The Net Investment income tax will not apply to any gain that is excluded from gross income for regular income tax purposes.

18 Example 1: Does this tax apply to gain on the sale of a personal residence? A, a single filer, earns $210,000. In wages and sells his principal residence that he has owned and resided in for the last 10 years for $420, A’s cost basis in the home is $200, A’s realized gain on the sale is $220, Under IRC section 121, A may exclude up to $250, of gain on the sale. Because this gain is excluded for regular income tax purposes, it is also excluded for purposes of determining Net Investment Income. In this example, the Net investment income tax does not apply to the gain from the sale of A’s home.

19 Example 2: Taxpayer, a single filer, has wages of $180,000 and $15,000 of dividends and capital gains. Taxpayer’s modified adjusted gross income is $195,000, which is less than the $200,000 statutory threshold. Taxpayer is not subject to the Net Investment income tax. MAGI $195,000 Threshold (200,000) Excess 0 =======

20 Example 3: Taxpayer, a single filer, has $180,000 of wages. Taxpayer also received 90,000 from a passive partnership interest, which is considered NII. Taxpayer’s MAGI is $270,000. Taxpayer’s MAGI exceeds the statutory threshold $200,000 for a single filer by $70,000. Taxpayer owes NIIT of $2,660. (70,000 X 3.8%). The NIIT is based on the lesser of $70,000(the amount that taxpayer’s MAGI exceeds the $200,000 threshold) or $90,000(taxpayer’s NII).

21 Additional 0.9 Percent Medicare Tax When does Additional Medicare Tax start? Additional Medicare Tax applies to wages and compensation above a threshold amount received after December 31, 2012 and to self-employment income above a threshold amount received in taxable years beginning after December 31, 2012.

22 Additional 0.9 Percent Medicare Tax What is the rate of Additional Medicare Tax? The rate is 0.9 percent. When are individuals liable for Additional Medicare Tax? An individual is liable for Additional Medicare Tax if the individual’s wages, compensation, or self- employment income exceed the threshold amount for the individual’s filing status:

23 Additional 0.9 Percent Medicare Tax Filing StatusThreshold Amount Married filing jointly$250,000 Married filing separately$125,000 Single$200,000 Head of household (with qualifying person) $200,000 Qualifying widow(er) with dependent child $200,000

24 Additional 0.9 Percent Medicare Tax What wages are subject to Additional Medicare Tax? All wages that are currently subject to Medicare Tax are subject to Additional Medicare Tax if they are paid in excess of the applicable threshold for an individual’s filing status. For more information on what wages are subject to Medicare Tax, see the chart, Special Rules for Various Types of Services and Payments, in section 15 of Publication 15, (Circular E), Employer’s Tax Guide.

25 Additional 0.9 Percent Medicare Tax Are nonresident aliens and U.S. citizens living abroad subject to Additional Medicare Tax? There are no special rules for nonresident aliens and U.S. citizens living abroad for purposes of this provision. Wages, other compensation, and self-employment income that are subject to Medicare tax will also be subject to Additional Medicare Tax if in excess of the applicable threshold.

26 Additional 0.9 Percent Medicare Tax Additional Medicare Tax goes into effect for taxable years beginning after December 31, 2012; however, the proposed regulations (REG ) are not effective until after the notice and comment period has ended and final regulations have been published in the Federal Register. How will this affect Additional Medicare Tax requirements for employers, employees, or self-employed?

27 Additional 0.9 Percent Medicare Tax Additional Medicare Tax applies to wages, compensation, and self-employment income received in tax years beginning after December 31, Taxpayers must comply with the law as of that date. With regard to specific matters discussed in the proposed regulations, taxpayers may rely on the proposed regulations for tax periods beginning before the date that the final regulations are published in the Federal Register. If any requirements change in the final regulations, taxpayers will only be responsible for complying with the new requirements from the date of their publication.

28 Additional 0.9 Percent Medicare Tax Will Additional Medicare Tax be withheld from an individual's wages? An employer must withhold Additional Medicare Tax from wages it pays to an individual in excess of $200,000 in a calendar year, without regard to the individual’s filing status or wages paid by another employer. An individual may owe more than the amount withheld by the employer, depending on the individual’s filing status, wages, compensation, and self-employment income. In that case, the individual should make estimated tax payments and/or request additional income tax withholding using Form W-4, Employee's Withholding Allowance Certificate.

29 Additional 0.9 Percent Medicare Tax Can I request additional withholding specifically for Additional Medicare Tax? No. However, if you anticipate liability for Additional Medicare Tax, you may request that your employer withhold an additional amount of income tax withholding on Form W-4. The additional income tax withholding will be applied against your taxes shown on your individual income tax return (Form 1040), including any Additional Medicare Tax liability.

30 Additional 0.9 Percent Medicare Tax Will I need to make estimated tax payments for Additional Medicare Tax? If you anticipate that you will owe Additional Medicare Tax but will not satisfy the liability through Additional Medicare Tax withholding and did not request additional income tax withholding using Form W-4, you may need to make estimated tax payments. You should consider your estimated total tax liability in light of your wages, other compensation, and self-employment income and the applicable threshold for your filing status when determining whether estimated tax payments are necessary.

31 Additional 0.9 Percent Medicare Tax Will individuals calculate Additional Medicare Tax liability on their income tax returns? Yes. Individuals liable for Additional Medicare Tax will calculate Additional Medicare Tax liability on their individual income tax returns (Form 1040). Individuals will also report Additional Medicare Tax withheld by their employers on their individual tax returns. Any Additional Medicare Tax withheld by an employer will be applied against all taxes shown on an individual’s income tax return, including any Additional Medicare Tax liability.

32 Additional 0.9 Percent Medicare Tax Will an individual owe Additional Medicare Tax on all wages, compensation, and/or self-employment income or just the wages, compensation, and/or self- employment income in excess of the threshold for the individual’s filing status? An individual will owe Additional Medicare Tax on wages, compensation, and/or self-employment income (and that of the individual’s spouse if married filing jointly) that exceed the applicable threshold for the individual’s filing status. For married persons filing jointly the threshold is $250,000, for married persons filing separately the threshold is $125,000, and for all others the threshold is $200,000.

33 Additional 0.9 Percent Medicare Tax If my employer withholds Additional Medicare Tax from my wages in excess of $200,000, but I won't owe the tax because my spouse and I file a joint return and we won't meet the $250,000 threshold for joint filers, can I ask my employer to stop withholding Additional Medicare Tax? No. Your employer must withhold Additional Medicare Tax on wages it pays to you in excess of $200,000 in a calendar year. Your employer cannot honor a request to cease withholding Additional Medicare Tax if it is required to withhold it. You will claim credit for any withheld Additional Medicare Tax against the total tax liability shown on your individual income tax return (Form 1040).

34 Additional 0.9 Percent Medicare Tax What should I do if I have two jobs and neither employer withholds Additional Medicare Tax, but the sum of my wages exceeds the threshold at which I will owe the tax? If you anticipate that you will owe Additional Medicare Tax but will not satisfy the liability through Additional Medicare Tax withholding (for example, because you will not be paid wages in excess of $200,000 in a calendar year by an employer), you should make estimated tax payments and/or request additional income tax withholding using Form W-4. For information on making estimated tax payments and requesting an additional amount be withheld from each paycheck, see Publication 505, Tax Withholding and Estimated Tax.

35 Additional 0.9 Percent Medicare Tax Are wages that are not paid in cash, such as fringe benefits, subject to Additional Medicare Tax? Yes, the value of taxable wages not paid in cash, such as noncash fringe benefits, are subject to Additional Medicare Tax, if, in combination with other wages, they exceed the individual’s applicable threshold. Noncash wages are subject to Additional Medicare Tax withholding, if, in combination with other wages paid by the employer, they exceed the $200,000 withholding threshold.

36 Additional 0.9 Percent Medicare Tax Are tips subject to Additional Medicare Tax? Yes, tips are subject to Additional Medicare Tax, if, in combination with other wages, they exceed the individual’s applicable threshold. Tips are subject to Additional Medicare Tax withholding, if, in combination with other wages paid by the employer, they exceed the $200,000 withholding threshold.

37 Additional 0.9 Percent Medicare Tax When must an employer withhold Additional Medicare Tax? The statute requires an employer to withhold Additional Medicare Tax on wages it pays to an employee in excess of $200,000 in a calendar year, beginning January 1, An employer has this withholding obligation even though an employee may not be liable for Additional Medicare Tax because, for example, the employee’s wages together with that of his or her spouse do not exceed the $250,000 threshold for joint return filers. Any withheld Additional Medicare Tax will be credited against the total tax liability shown on the individual’s income tax return (Form 1040).

38 Additional 0.9 Percent Medicare Tax Is an employer liable for Additional Medicare Tax even if it does not withhold it from an employee’s wages? An employer that does not deduct and withhold Additional Medicare Tax as required is liable for the tax unless the tax that it failed to withhold from the employee’s wages is paid by the employee. Even if not liable for the tax, an employer that does not meet its withholding, deposit, reporting, and payment responsibilities for Additional Medicare Tax may be subject to all applicable penalties.

39 Additional 0.9 Percent Medicare Tax Is an employer required to notify an employee when it begins withholding Additional Medicare Tax? No. There is no requirement that an employer notify its employee. Is there an “employer match” for Additional Medicare Tax (as there is with the regular Medicare tax)? No. There is no employer match for Additional Medicare Tax.

40 Additional 0.9 Percent Medicare Tax May an employee request additional withholding specifically for Additional Medicare Tax? No. However, an employee who anticipates liability for Additional Medicare Tax may request that his or her employer withhold an additional amount of income tax withholding on Form W-4. This additional income tax withholding will be applied against all taxes shown on the individual’s income tax return (Form 1040), including any Additional Medicare Tax liability.

41 Additional 0.9 Percent Medicare Tax If an employee’s annual Medicare wages are expected to be over $200,000, will an employer withhold Additional Medicare Tax from the beginning of the year or only after Medicare wages are actually paid in excess of $200,000 year-to- date? An employer is required to begin withholding Additional Medicare Tax in the pay period in which it pays wages in excess of $200,000 to an employee.

42 Additional 0.9 Percent Medicare Tax If a single payment of wages to an employee exceeds the $200,000 withholding threshold, will an employer withhold Additional Medicare Tax on the entire payment? No. Additional Medicare Tax withholding applies only to wages paid to an employee that are in excess of $200,000 in a calendar year. Withholding rules for this tax are different than the income tax withholding rules for supplemental wages in excess of $1,000,000 as explained in Publication 15, section 7.

43 Additional 0.9 Percent Medicare Tax I have two employees who are married to each other. Each earns $150,000, so I know that their combined wages will exceed the threshold applicable to married couples that file jointly. Do I need to withhold Additional Medicare tax? No. An employer should not combine wages it pays to two employees to determine whether to withhold Additional Medicare Tax. An employer is required to withhold Additional Medicare Tax only when it pays wages in excess of $200,000 in a calendar year to an employee.

44 Additional 0.9 Percent Medicare Tax What should an employer do if an employee receives wages that are not paid in cash, such as taxable fringe benefits, from which Additional Medicare Tax cannot be withheld? If an employee receives wages from an employer in excess of $200,000 and the wages include taxable noncash fringe benefits, the employer calculates wages for purposes of withholding Additional Medicare Tax in the same way that it calculates wages for withholding the existing Medicare tax. The employer is required to withhold Additional Medicare Tax on total wages, including taxable noncash fringe benefits, in excess of $200,000. The value of taxable noncash fringe benefits must be included in wages and the employer must withhold the applicable Additional Medicare Tax and deposit the tax under the rules for employment tax withholding and deposits that apply to taxable noncash fringe benefits. Additional information on how to withhold tax on taxable noncash fringe benefits is available in Publication 15 (Circular E), section 5, and Publication 15-B, section 4.

45 Additional 0.9 Percent Medicare Tax If an employee receives tips and other wages in excess of $200,000 in the calendar year, how is Additional Medicare Tax paid on the tips? To the extent that tips and other wages exceed $200,000, an employer applies the same withholding rules for Additional Medicare Tax as it does currently for Medicare tax. An employer withholds Additional Medicare Tax on the employee’s reported tips from wages it pays to the employee. If the employee does not receive enough wages for the employer to withhold all the taxes that the employee owes, including Additional Medicare Tax, the employee may give the employer money to pay the rest of the taxes. If the employee does not give the employer money to pay the taxes, then the employer makes a current period adjustment on Form 941, Employer’s QUARTERLY Federal Tax Return (or the employer’s applicable employment tax return), to reflect any uncollected employee social security, Medicare, or Additional Medicare Tax on reported tips. However, unlike the uncollected portion of the regular (1.45%) Medicare tax, the uncollected Additional Medicare Tax is not reported in box 12 of Form W-2 with code B. The employee may need to make estimated tax payments to cover any shortage.

46 TAX MATTERS Self-employed can deduct Medicare Premiums, IRS Chief Counsel Advises. Chief Counsel Advise (CCA) Clarifies an IRS position allowing the deduction. Taxpayers who failed to deduct Medicare premiums for prior years within the statute of limitation period may file amended returns to claim the deduction.

47 TAX MATTERS J. Martinez, T.C. Memo , December 59,298(M). Noncustorial parent denied dependency exemptions and child tax credits despite marital settlement agreement entitling him to both; children were not dependents in absence of written declaration.

48 TAX MATTERS IRS offers new penalty relief and expanded installment agreements to taxpayers under expanded fresh start initiative. IR , March 7, Under the new fresh start provisions, part of a broader effort started at the IRS in 2008, certain taxpayers who have been unemployed for 30 days or longer will be able to avoid failure to pay penalties. In addition, the IRS is doubling the dollar threshold for taxpayers eligible for installment agreements to help more people qualify for the program.

49 TAX MATTERS Penalty Relief: The IRS announced plans for new penalty relief for the unemployed on failure to pay penalties which are one of the biggest factors a financially distressed taxpayer faces on a tax bill.

50 TAX MATTERS To assist those most in need, a six month grace period on failure-to-pay penalties will be made available to certain wage earners and self- employed individuals. The request for an extension of time to pay will result in relief from failure to pay penalty for tax year 2011 only if tax, interest and any other penalties are fully paid by October 15, 2012.

51 TAX MATTERS The penalty relief will be available to two categories of taxpayers: – Wage earners who have been unemployed at least 30 consecutive days during 2011 or in 2012 up to the April 17 deadline for filing a federal tax return this year. – Self-employed individuals who experienced a 25% or greater reduction in business income in 2011 due to the economy.

52 TAX MATTERS This penalty relief is subject to income limits. A taxpayer’s income must not exceed $200,000 If he or she files as married filing jointly or not exceed $100,000 If he or she files single or head of household. This penalty relief is also restricted to taxpayers whose calendar year 2011 balance due does not exceed $50,000.

53 TAX MATTERS Taxpayers meeting the eligibility criteria will need to complete a new Form 1127A to seek the 2011 penalty relief. The new form is available on IRS.gov. The failure to pay penalty is generally half of 1 percent per month with an upper limit of 25%. Under this new relief, taxpayers can avoid that penalty until October 15, However the IRS is still legally required to charge interest on unpaid back taxes and does not have the authority to waive this charge, which is currently 3 percent on an annual basis. Even with new penalty relief available, you should file your return on time to avoid the Failure to file penalty which is 5% per month, also with a 25% cap.

54 Installment Agreements The fresh start provision also means that more taxpayers will have the ability to use streamlined installment agreements to catch up on back taxes. The IRS announced that, effective immediately, the threshold for using an installment agreement without having to supply the IRS with a financial statement has been raised from $25,000 to $50,000. This is a significant reduction in taxpayer burden.

55 Installment Agreements Taxpayers who owe up to $50,000 in back taxes will now be able to enter into a streamlined agreement with the IRS that stretches the payment out over a series of months or years. The maximum term for streamlined installment agreement has also been raised to 72 months from the current 60-month maximum. Taxpayers seeking installments exceeding $50,000 will still need to supply the IRS with a collection information statement (Form 433-A or 433-F). Taxpayers may also pay down their balance due to $50,000 or less to take advantage of this payment option.

56 Installment Agreements An installment agreement is an option for those who cannot pay their entire tax bills by the due date. Penalties are reduced, although interest continues to accrue on the outstanding balance. In order to qualify for the new expanded streamlined installment agreement, a taxpayer must agree to monthly direct debit payments. Taxpayers can setup an I/A with the IRS by going to the On-line payment agreement (OPA) page on IRS.gov and following the instructions.

57 Offers in Compromise The IRS recognizes that many taxpayers are still struggling to pay their bills so the agency has been working to put in place more common-sense changes to the OIC program to more closely reflect real world situations. Example, The IRS has more flexibility with financial analysis for determining reasonable collection potential for distressed taxpayers. A series of short videos are available to familiarize taxpayers and practitioners with the IRS collection process. (IRS.gov).

58 When a taxpayer’s records are lost or destroyed through circumstances beyond the taxpayer’s control, the taxpayer is entitled to substantiate deductions by reconstructing expenditures through credible evidence. However, a court is not bound to accept unverified, undocumented testimony of a taxpayer.

59 If the record provides sufficient evidence that a taxpayer has incurred a deductible expense, but the taxpayer is unable to adequately substantiate the precise amount of the deduction to which he or she is otherwise entitle, the court may estimate the amount of the deductible expense and allow the deduction to that extent, bearing heavily against the taxpayer whose inexactitude in substantiating the amount of the expense is of his or her own making. (Cohan v. Commissioner) The court must have some basis upon which an estimate may be made.

60 Federal Tax Day - Current,J.6,Debtor’s CDP Hearing Request Tolled Look-Back Period; Tax Debts Not Dischargeable (In re Lastra, BC-DC N.M.),(Dec. 28, 2012) A debtor’s federal income tax liabilities were not dischargeable in bankruptcy. Although the debtor filed his returns more than three years prior to the filing of his bankruptcy petition, his Collection Due Process (CDP) hearing request tolled the three-year look-back period and, therefore, the debtor’s petition was filed before the three-year look-back period ended. In re P. Lastra, BC-DC N.M., USTC ¶50,116

61 Issues & Cases Alan J. Harriet, MBA, CPA Appeals Domestic Operations Technical Specialist

62 Self Employment Taxes for LLC Members IRC Section 1402(a)(13) Renkemeyer, Campbell, and Weaver, LLP v. Commissioner, 136 T.C. No. 7 (2/9/2011)

63 Real Estate Professional Real Estate Professional IRC Section 469(c)(7) William Harnett, et ux v. Commissioner, T.C. Memo (8/11/201), 110 A.F.T.R. 2d , 11 th Circuit (11/14/2012)

64 Six Year Statute for 25% Omission of Income Six Year Statute for 25% Omission of Income IRC Section 6501(e) United States v. Home Concrete and Supply, LLC, 132 S.Ct (4/25/2012)

65 Loss for Worthless Partnership Interests and Abandonments Loss for Worthless Partnership Interests and Abandonments – IRC Section 165 John C. and Deanna O. Echols v. Commissioner, 93 T.C. No. 45, (11/6/1989), 935 F.2d 703, 5 th Circuit (7/15/1991) Tejon Ranch Company and Subsidiaries v. Commissioner, T.C. Memo (4/30/1985) B. Philip and Emily K. Citron v. Commissioner, 97 T.C. No. 12 (8/5/1991)

66 Guaranteed Payments Guaranteed Payments IRC Section 707(c) Edward T. and Billie R. Pratt, et al v. Commissioner, 64 T.C. 203, (5/8/1975), 550 F.2d 1023, 5 th Circuit (4/14/1977)

67 Material Participation for LLC Members Material Participation for LLC Members IRC Section 469(h)(2) Paul D. and Alicia Garnett v. Commissioner, 132 T.C. No. 14 (6/30/2009) James R. Thompson v. United States, 87 Fed. Claims 728 (7/20/2009) Lee E. and Kathy H. Newell v. Commissioner, T.C. Memo (2/16/2010)

68 Partnership Disguised Sales Partnership Disguised Sales IRC Section 707(a) John H., Jr. and Bettye G. Otey v. Commissioner, 70 T.C. 312 (5/23/1978) Non-Acquiesce

69 Partnership Allocations Partnership Allocations IRC Section 704 Stanley C. and Gerta E. Orrisch v. Commissioner, 55 T.C. 395 (12/2/1970)


Download ppt "2012 IRS Tax Updates and Current Developments. Presented by … Raul O. Serrano, Jr. C.P.A. www.SerranoCPA.net."

Similar presentations


Ads by Google