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- Can the IRS’s Automated System Issue a Valid Notice of Deficiency?Every year, millions of taxpayers receive letters from the IRS proposing adjustments to their tax returns. Most people assume those letters came from a human being who reviewed the file, weighed the facts, and made a considered decision to send the notice. That assumption is increasingly wrong. The IRS relies heavily on automated systems to…… Continue reading Can the IRS’s Automated System Issue a Valid Notice of Deficiency?
- Who Gets the Tax Credit When You Outsource Payroll to a PEO?Many businesses outsource their payroll, human resources, and employment tax responsibilities to professional employer organizations. These arrangements make sense. The PEO handles the administrative burden of onboarding workers, processing wages, withholding taxes, and managing benefits. The business owner focuses on running the business and directing the workers. But when it comes time to claim employment-related…… Continue reading Who Gets the Tax Credit When You Outsource Payroll to a PEO?
- Selling a Furnished Vacation Home: Allocating Between Real & Personal PropertyA vacation home is nice to have. Many vacation homes are owned for years–if not decades. The capital gains tax can be substantial when the owner goes to sell the property. And unlike a primary residence, the $250,000 or $500,000 gain exclusion under Section 121 is not available for a property that was never the…… Continue reading Selling a Furnished Vacation Home: Allocating Between Real & Personal Property
- Can Corporate Suspension Foreclose U.S. Tax Court ReviewThere are a number of administrative rules that businesses have to comply with. This can create administrative headaches for businesses–particularly small businesses. The requirement for annual maintenace of state corporate status is an example. Businesses, particularly small businesses, often fail to meet annual state filing requirements. The result is that their corporate powers are limited.…… Continue reading Can Corporate Suspension Foreclose U.S. Tax Court Review
- Can the IRS Walk Away from an Installment Agreement?Taxpayers who owe the IRS back taxes often try to work out terms with the IRS for the balance. This often involves an installment agreement. Once established, the IRS often terminates the agreements and it often does so without any notice or explanation as to why it did so. This can be extremely frustrating for…… Continue reading Can the IRS Walk Away from an Installment Agreement?
- Contribution of A Note to a Subsidiary: The Zero-Basis RuleBusinesses organized through multiple related entities routinely use promissory notes to move money between them. A parent company may issue a note to a subsidiary to capitalize it or fund operations. Affiliates lend to one another as part of ordinary treasury management. In the partnership context, a partner who wants to demonstrate additional financial commitment—but…… Continue reading Contribution of A Note to a Subsidiary: The Zero-Basis Rule
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