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  • Simplify Your Tax Research

    Tax Research the Way You Want It Prefer to research tax issues by IRC section? By topic? Either way, LexisNexis® Tax Center makes it easy for you to access exclusive, authoritative analytical materials from CCH®*, Tax Analysts®, Shepard's...
  • Take the Money and Run: Extracting Equity on a Tax-Free Basis

    A partnership is often chosen over other structures as the tax entity best suited for the conduct of a business. Inevitably, taxpayers and their advisors must consider the disposition or monetization of their interest in that business. Extracting a taxpayer's...
  • A Comprehensive Analysis of the "Stimulus Bill"

    On February 17, 2009, President Obama signed major new legislation known as the “stimulus bill” which provides $787 billion of tax incentives and spending provisions to improve the economy. To understand the tax implications for your clients...
  • Tax Court Pretrial Procedures: Pretrial Orders and Conferences, Motions, and Settlement

    I. STANDING PRETRIAL ORDER A. All Judges Now Use the Same Standing Pretrial Order. 1. The Court attaches the Standing Pretrial Order to the Notice Setting Case For Trial. 2. The Notice Setting Case For Trial is usually received about six months...
  • Treasury and IRS Release Report Addressing Strategy to Improve Voluntary Compliance with Tax Laws

    On August 2, 2007, the Treasury Department and the IRS released a report titled “Reducing the Federal Tax Gap.” The report addresses the IRS’s strategy for reducing the tax gap. The report includes seven components and sets out compliance...
  • Tax-Advantaged Transactions: Controversy and Planning Abound

    The 2006 Federal Circuit Court of Appeals ruling in Coltec Industries, Inc. v. United States has given the Internal Revenue Service another weapon in its aggressive enforcement efforts against taxadvantaged transactions that are specifically structured...
  • Administrative Procedures: Representation Before the IRS Appeals Office

    A most important option available to a taxpayer is to appeal proposed audit adjustments to the IRS Appeals Office. Congress agrees and the IRS Restructuring and Reform Act of 1998, Pub. L. 105-206 (the "98 Act") required the Service reorganization...
  • Circular 230 "Best Practices" and Written Advice Standards

    Final Regulations under Circular 230, issued on December 20, 2004 (T.D. 9165) and as amended May 18, 2005 (T.D. 9201), establish standards for tax "practitioners" providing Covered Opinions and Other Written Advice as well as "best practices"...
  • Federal Income Tax Considerations in the Choice of Business Entity

    I. Choices of Business Entity. A. Sole proprietorship. In conducting a business as a "sole proprietorship", an individual (the "sole proprietor") typically segregates a portion of his or her assets and dedicates them to a specific...
  • Understanding Corporate Taxation

    Introduction to the “Corporate Tax” and Resulting Double Taxation A “corporation” is a legal entity created under a state or other statute that allows “incorporation” by persons who become the “shareholders”...
  • Scam: Income Tax Refund Under Section 501(c)(3)

    Unfortunately, many citizens not familiar with Section 501(c)(3), are falling for a spam scam. The IRS is reporting that thieves are using a method called phishing, a technique used to acquire personal financial data in order to gain access to the financial...
  • American Recovery and Reinvestment Act of 2009

    On February 17, 2009 President Obama signed into law the much publicized American Recovery and Reinvestment Act of 2009 (ARRA) which contained $787 billion worth of tax incentives and spending provisions intended to help revitalize the economy. The provisions...
  • Adding Injury to Insult -- Getting the IRS to Pay Your Fees

    Section 7430 (a) and (b) provide a taxpayer the right to recover costs, including fees of experts and attorneys paid or incurred: 1. In an administrative or court proceeding brought by or against the United States; 2. In which the taxpayer is the...
  • Appealing an Audit

    If your client can't stomach the tax bill received after an IRS audit, you may want to appeal to the IRS for a second look. So many taxpayers are able to downsize the amount of taxes, interest, and penalties owed by appealing that IRS agents grudgingly...
  • Could you repeat that, please?

    Just starting out in the Tax Law field? A basic knowledge of the terms of art is key to impressing your client or managing partner with your ability to handle Tax Law matters competently. Read on for a quick primer! Actions on Decisions - It is the...