Rates, Tables, Statutory Amounts & Highlights. 1
Standard Deduction. 3
Dependent Limit 3
Election to Report on Parent’s Return. 3
Phaseout of Exemptions - 2% Haircut 3
Overall Limitation on Itemized Deductions - 3% Haircut 4
Earned Income Credit - §32. 4
Social Security & Self-Employment Earnings Base. 5
Cents-Per-Mile Rates - Standard Mileage Rate. 5
Qualified Transportation Fringes. 5
Passenger Automobile Depreciation Limits. 6
Expensing Deduction - §179. 6
Self-Employed Health Insurance Deduction. 6
Corporate Income Tax Rates. 6
Recent Legislative Highlights. 6
Standard Deduction Increase for Married Persons. 6
15% Tax Bracket Will Expand for Married Persons Filing Jointly. 7
Exemption Amount Increases. 7
Elimination of Limit on Itemized Deductions - 3% Haircut 7
Elimination of Phaseout of Personal Exemptions - 2% Haircut 7
Tuition & Fees Deduction. 8
Hours of Service Meal Limits. 8
Repeal of Archer Medical Savings Accounts. 8
Health Savings Accounts (HSAs) 9
Old Medical Savings Accounts Gone. 9
Benefits. 10
Qualifications. 10
High Deductible Health Plan (HDHP) 11
Limits. 11
Amount of Contribution. 12
Special Rules for Married Couples. 13
Establishing an HSA.. 14
Rollovers. 14
Distributions. 14
Qualified Medical Expenses. 14
Insurance Premiums. 14
Recordkeeping. 15
Qualified Plans. 15
Defined Benefit Plan Limits. 15
Defined Contribution Plan Limits. 15
Elective Deferrals Treated as Roth Contributions. 15
Modified AGI Limit for Traditional IRAs. 17
Increase in Limits on Elective Deferrals under a SEP-IRA.. 17
Simplified Employee Pensions (SEPs) 17
Additional Elective Deferrals under a SEP-IRA for Persons 50 & Older 17
Increase In Limit on Salary Reduction Contributions under a SIMPLE. 18
Additional Salary Reduction Contributions to SIMPLE IRAs for Persons 50 & Older 18
Increased Estate & GST Exemption. 18
Scheduled Repeal of Estate & GST Taxes. 18
Reduction of Credit for State Death Taxes. 19
Social Security and Medicare Taxes. 19
Self-employment Tax. 19
Expensing Under §179. 19
§179 Extended Through 2007. 19
§179 on SUVs Under 14,000 GVW limited to $25,000. 20
Expensing of Environmental Remediation Costs (§198) 21
Standard Mileage Rate. 21
Alternative Motor Vehicles. 21
Electric Vehicles. 22
Start-Up Costs & Organizational Costs. 23
Qualifying Costs. 23
Purchasing An Active Trade Or Business. 24
Leasehold Improvements & Restaurant Property. 24
Qualified Restaurant Property. 24
Leasehold Improvements. 24
Qualified Improvement Property. 24
Deduction for Domestic Production Activities. 25
Qualified Production Activities Income. 26
Passthrough Entities. 26
Limits On The Deduction. 27
Alternative Minimum Tax. 27
Income Averaging for Farmers & Fishermen. 27
Research Credit 28
Work Opportunity Tax Credit 28
Welfare-to-Work Tax Credit 29
Charitable Contributions of Computer Equipment 30
Treatment of Nonqualified Deferred Compensation Plans - §409A.. 30
Section 1202 Exclusion Increased. 31
Timber 31
Expensing Reforestation Costs. 31
Capital Gain on Outright Sales of Timber 31
S Corporations. 32
Number of Shareholders. 32
Family Members Treated As One Shareholder 32
Transfer of Suspended Losses. 32
Electing Small Business Trusts. 33
Grandfathered IRAs Allowed to Hold Bank S Stock. 33
Charitable Contribution of Patents. 34
Employment Taxes on Employee Stock Options. 35
Increase to FUTA Tax Deposit Requirement 35
Nanny Tax Threshold. 36
Revised Schedule M-3. 36
Reinvest Foreign Earnings Deduction. 37
Depreciation After an Exchange or Conversion. 37
Energy Policy Act of 2005. 38
Four Point Impact 38
Provisions of General Importance. 39
Alternative Technology Vehicle Credits. 39
Credit For Residential Energy Efficient Property Purchases. 42
Credit For Business Installation Of Qualified Equipment 42
Credit For Energy Efficient Existing Homes - §25C.. 43
Business Credit Of Energy Efficient New Homes - §45L. 44
Energy Efficient Commercial Building Deduction - §179D.. 45
Energy Efficient Appliances. 47
Research & Development Credit For Energy Research. 47
Selected Provisions That Expired in 2005. 47
Individual Matters. 49
Taxpayer Not Single until Divorce Decree Issued - §1. 49
Residency Test for Head of Household - §2. 50
Foreign Adoption Guidance - §23. 51
Guidance on Lean Burn & Hybrid Vehicles - §30B.. 53
Waiver of Low-Income Housing Credit Recertification - §42. 54
Low-Income Housing Credit Questions - §42. 54
Share of Co-op Property Taxes Isn't Deductible for AMT - §55. 56
Stock Option Schemes to Avoid AMT - §56. 57
AMT Deduction for Refinanced Home Mortgage Interest - §56. 58
Contingency Fees Includable in Taxpayer's Income - §61. 62
Supreme Court to Resolve Contingent Legal Fee Issue - §61. 63
Bonus Was Not Gift - §61. 64
Credit Card Insurance Creates Income - §61. 65
Sham Trust Creates Income - §61. 66
Damages for Faulty Home Construction Held Tax-free - §61. 67
Schedule C Loss Does Not Reduce Standard Deduction - §63. 68
Circumstantial Evidence Proves Gambling Losses - §63. 69
Unallocated Support Payments Not Alimony - §71. 70
Postdeath Substitute Payments Not Deductible - §71. 72
Payments Prior to Written Agreement Not Alimony - §71. 72
Amounts Paid to Ex-spouse Not Taxed to Wage Earner - §71. 73
State Law Terminated Payments at Death - §71. 76
Alimony Must Be Paid in Cash or Cash Equivalent - §71. 76
Medical Expense Distribution from Retirement Plan - §72. 77
10% Penalty for Early Withdrawal from Wrong Account - §72. 77
Unrepaid Loan Was Early Distribution Subject to Penalty - §72. 78
Taxpayer Not Disabled - 10% Penalty Applied - §72. 78
Interest Portion of Personal Injury Award Income - §104. 79
Social Security Disability Payments Held Income - §104. 80
Employees May Exclude Disability Benefits - §105. 81
Forgiveness Results in COD Income to Employee - §108. 82
Acknowledgement Precludes Dispute Exception - §108. 83
COD Insolvency Exception - §108. 84
Protesting Neighbors Ruled Unforeseen - §121. 87
Final Regs. On Sale of Principal Residence - §121. 88
Ex-spouse Permitted Home Sale Exclusion After 3 Years - §121. 95
Rulings Highlight “Unforseen Circumstances” - §121. 96
Form 8332 Trumps Divorce Decree - §152. 97
Deduction Allowed Despite Lack of Form 8332 - §152. 98
Divorce Decree Disregarded - §152. 100
Regs on Dividend Income Treated as Investment Income - §163. 102
Final Regs on Dividend Income as Investment Income - §163. 103
Loan Origination Fee Not Always Deductible - §163. 103
Claiming Sales Tax Deductions - §164. 104
No Theft Loss for Corporate Misconduct - §165. 105
Unreported Winnings Reduce EITC - §165. 106
Taxpayer Not a Professional Gamber - §165. 107
Bad Stock Investment Not Due to Theft - §165. 109
Employee's Bad Debt is Misc. Itemized Deduction - §166. 109
Costs of Obtaining Zoning Variances Depreciable - §167. 110
Publications on Automobile Donations - §170. 111
Improper Charitable Donations of Real Property - §170. 112
Consideration Received Denies Charitable Deduction - §170. 112
Guidance on Conservation Easements - §170. 113
Evaluation of Donated Vehicles - §170. 115
Contemporaneous Written Acknowledgment Required - §170. 119
Vehicle Proceeds of $500 or Less - §170. 120
More Guidance on Auto Donations - §170. 120
Gifts Held Qualified Conservation Easements - §170. 123
Charitable Deduction Limited to Gross Proceeds - §170. 125
Religious Tuition Not Deductible - §170. 126
Vehicle Donations Affected by GO Zone Act - §170. 126
Frequent Trades Still Held Investment Expense - §212. 128
Personal Residence Legal Fees Not Investment Expense - §212. 129
Deduction for Life Care Service Fees - §213. 129
No Medical Deduction for Commuting - §213. 131
Tuition Paid Results in Deductible Medical Expense - §213. 131
No Deduction for Imported Prescription Drugs - §213. 133
Regs on Qualified Education Loan Interest - §221. 134
HSA Safe Harbor for Preventive Care Benefits - §223. 135
HSA Relief on Qualified Medical Expense Rules - §223. 135
HSA Relief for Prescription Drug HDHP Plans - §223. 135
HSA Rules on Interaction of HDHP Benefits - §223. 136
Interaction of HSAs, HRAs, FSAs, and HDHPs - §223. 137
Additional Guidance on HSAs - §223. 138
Guidance on Partnership & S Corporation HSAs - §223. 139
Anti-Alienation Right for Retirement Plans - §401. 141
Retirement Funds Protected Under New Bankruptcy Act - §401. 141
Regs on Insurance Values When Distributed - §402. 148
Determining FMV of Life Insurance - §402. 148
Rollover Treatment Disallowed For Annuity - §402. 149
Waiver of IRA 60-Day Rollover - §408. 150
Waiver of Rollover Period Denied - §408. 154
Good Excuses for Waiver of 60-day Rollover - §408. 155
Bankruptcy Exemption for IRAs - §408. 157
Settlement Converted to QDRO - §414. 160
QDRO Claims of Participant's Children Denied - §414. 164
Real Estate Professionals Must Keep Records - §469. 167
Rental Trap Denies Passive Treatment - §469. 167
$25,000 Allowance - §469. 168
Individuals Cannot Net Income and Loss From Rentals - §469. 168
Extraordinary Personal Services Real Estate Exception - §469. 169
Successful Use of Incidental Rental Exception - §469. 170
No "Deemed Election" to Aggregate Rentals - §469. 173
Education Savings Accounts & Bankruptcy - §529. 175
Employees Who Die In Terrorist or Military Action - §692. 178
Income from Fishing in International Waters - §861. 179
Nonresident Alien's Lottery Payments Income - §871. 181
Transfer of Borrowed Stock Failed to Close Short Sale - §1001. 182
Regs on Depreciation of Exchanged MACRS Property - §1031. 182
'Parking' Transaction Safe Harbor Limited - §1031. 183
Exchanges of Interests in Delaware Statutory Trusts - §1031. 184
Determining Like-Kind Personal Property Classes - §1031. 185
Exchange Deadlines May Be Postponed - §1031. 186
Home-Sale Exclusion and Like-Kind Exchange - §1031. 186
Disposition Within Two Years Triggers Gain - §1031. 192
Undivided Fractional Interests Qualify for Exchange - §1031. 193
Old-Growth for New-Growth Timberland OK §1031. 196
Modification of QDRO Tax-Deferred - §1041. 196
Retirement Plan Transfer Ruled Incident to Divorce - §1041. 197
Gain on Sale of Stock to ESOP - §1042. 198
Assignment of Lottery Winnings Results in Income - §1221. 199
Bankruptcy Denies Individual S Corporations' Losses - §1398. 199
District Court Acquits Pilot Charged With Tax Evasion - Misc. 201
Protester's Tax Battle Ends With Settlement - Misc. 201
IRS Lists Common Filing Mistakes - Misc. 202
IRS Advises Individuals on Tax-Dodging Schemes - Misc. 204
IRS Reaffirms Same-Sex Marriage Position - §Misc. 208
2006 "Dirty Dozen" - Misc. 208
Two Fall off the List 212
How to Report Suspected Tax Fraud Activity. 213
Bankruptcy & Debtors' Tax-filing Responsibilities - Misc. 213
Guidance on SSA Earnings Test - Misc. 214
Business Matters. 216
Research Credit Recordkeeping Agreements - §41. 216
Failed Merger's Termination Fee Is Ordinary Income - §61. 216
Employer Relocation Home Sale Programs - §61. 217
Mileage Allowance Paid Under Accountable Plan - §62. 219
Taxpayer Violates Return of Excess Rule - §62. 220
Mechanics' Tool Reimbursements Taxable - §62. 221
Unreimbursed Employee Business Deductions Limited - §67. 223
When Employee Recognizes Compensation Income - §83. 224
Shares Transferred When Options Exercised - §83. 225
Stock Option Income on Date of Exercise - §83. 226
Medical Reimbursement Plan Payments Taxable - §105. 227
Bargain Sale of Land Held Capital Contribution - §118. 231
IRS Halts Fringe Benefits Arrangement - §132. 232
Phony Home Office Deductions - §162. 232
Taxes Paid on Behalf of Two Partnerships Deductible - §162. 233
Unreimbursed Partnership Expenses Denied - §162. 234
Taxpayers Cannot Deduct S Corporation's Expenses - §162. 236
Bonus Can Not Be Treated as Gift - §162. 236
Salary Deduction Paid to Kids Denied - §162. 238
Jet Engine “Overhaul” Deemed Maintenance - §162. 239
Boat Engine “Overhaul” Deemed Maintenance - §162. 241
Itinerant Worker Has No Away-from-Home Expenses - §162. 243
Fringe Benefit Audit Technique Guide - §162. 243
Guidance on Self-Employed Health Insurance Deduction - §162. 245
Travel and Bodybuilding Expenses Allowed - §162. 247
Cost of MBA Deductible - §162. 248
No Deduction Based Merely on Statistical Information - §162. 252
Deduction Allowed for Most of CEO's Compensation - §162. 253
Per Diem Rates for Post September 30, 2005 - §162. 254
Truck Lease Expenses Not Deductible on Schedule C - §162. 257
Loans Held Capital Investments - §163. 259
Company Not Entitled to Abandonment Loss - §165. 260
Gambling Winnings Includible in Income - §165. 261
Worthlessness of Debt in Year Claimed Not Proved - §166. 262
Regs on Depreciation Property When Use Changes - §168. 263
Depreciation Deduction Limitations for Autos in 2005 - §168. 263
Home Office May Be 27.5-year “Residential Property” - §168. 264
Cost Segregation Audit Techniques Guide - §168. 266
Development Rights Associated Partially Deductible - §168. 271
Without Election NOL Must Be Carried Back First - §172. 273
Regs on §179 Election & Revocation Rules - §179. 274
Revoke §179 Election Without IRS Consent - §179. 274
Property Deductions Limited Under “Hobby Loss” Rules - §183. 277
Mary Kay Sales Activity Not for Profit - §183. 278
Amway Distributorship Held Not for Profit - §183. 280
Lesser Standard for Playwrights & Artists - §183. 281
Horse Breeding Activities Lacked Profit Motive - §183. 283
12 Years of Leasing Losses Still for Profit - §183. 284
Drag Racing Losses Deductible - §183. 286
Guidance on US Production Deduction - §199. 289
Proposed Regs on US Production Deduction - §199. 297
Proposed Break for Developers & Homebuliders - §199. 309
Technical Corrections to Production Deduction - §199. 311
2½ Month Grace Period Could Adversely Affect HSAs - §223. 315
Two Ways to Handle HSA Eligibility & 2½ -Month Rule - §223. 317
Regulatory Guidance on HSA Comparability Rule - §223. 319
Guidance on Capitalization of Intangibles - §263. 323
Patent Infringement Must Be Capitalized - §263. 324
Manufacturer Must Capitalize Clean-Up Costs - §263. 325
Guidance on Interest Deduction Disallowance - §265. 326
Trucking Company's Per Diem Limited - §274. 327
Statistical Sampling Method - §274. 328
Yacht Was Non-Deductible Entertainment Facility - §274. 329
Digital Documentation Satisfies Adequate Accounting - §274. 331
Business Expenses Disallowed Records Insufficient - §274. 332
Entertainment Use of Business Aircraft - §274. 334
Driver-Leasing Company Subject to Limitation - §274. 336
Final Regs on Rules for “Nonpersonal Use Vehicles" - §280F. 337
Sub's Distribution of Parent Indebtedness - §301. 339
Owner Granted Redemption Treatment - §302. 340
Business Purpose Satisfied - §355. 343
Regs on Spinoffs - §355. 343
Regs Ease Rules on Stock and Asset Reorganizations - §368. 344
Regs on Stock Basis Determinations - §368. 344
Debt Instruments in Corporate Reorgs - §368. 345
Regs on Exclusion of DOI Income - §381. 346
NOLs Limited After Stock Sale - §382. 346
Nondiscrimination Rules for Plans with Insurance - §401. 349
Regs on Minimum Distribution Rules - §401. 349
Roth-like Contributions to Be Allowed in Qualified Plans - §401. 350
Regulatory Guidance on Roth 401(k)s - §401. 351
Early Distributions For Phased Retirement Programs - §401. 353
Roth 401(k) Final Regulations - §402A.. 356
Proposed Regs on ESOPs Holding S Corp Stock - §409. 357
Guidance on Deferred Compensation Plan Rules - §409A.. 357
Guidance on Nonqualified Deferred Comp Rules - §409A.. 357
Reporting & Withholding Suspended - §409A.. 362
Amendment Violates ERISA's Anticutback Rule - §411. 364
Partial Termination' of ERISA Pension Plans - §411. 365
Plan Deductions Limited If Excessive Life Insurance - §412. 366
Pension Funding Equity Act of 2004 - §412. 367
New Interest Rate for Pension Plan Funding - §412. 368
Safe Harbor Method for Creative Property Costs - §446. 368
Advance Payments Eligible for Deferral - §451. 368
Credit Card Annual Fees Are Not Interest Income - §451. 373
Agricultural Co-Op Income Constructively Received - §451. 374
Regs Broaden Scope of At-Risk Rules - §465. 375
Ventures between Exempt Organizations & For-Profits - §501. 381
Calculation of Accumulated Earnings Tax - §531. 381
Regs on Partnership Allocations for Foreign Taxes - §704. 383
Amortization Allocations Allowed - §704. 384
Disguised Sales of Partnership Interests - §707. 384
Partnership Treatment of Installment Obligations Regs - §704. 385
Claimed Termination Date Disregarded - §708. 387
Recourse Liability Not Allocable to LLC - §752. 388
Regs on Treatment of Disregarded Entities - §752. 389
Loan Payment Results in Income - §752. 390
Regs on Effect of Liabilities and SMLLC Basis Rules - §752. 390
Partnership's Sale of Qualified Small Business Stock - §1045. 391
Classic Cars Not Capital Assets - §1221. 392
Developer Gets Capital Gains on Sale of Raw Land - §1221. 395
Late Community-Property S Shareholder Consents - §1361. 397
Tribe Not Qualified to Be S Corporation Shareholder - §1361. 399
Effect of Reorganizations on QSub - §1361. 399
S Election Not Terminated by Distributions - §1361. 400
IRS Waives Inadvertent Termination - §1361. 401
Bankruptcy Doesn’t Terminate S Election - §1361. 401
Making S Corporation Family Shareholder Election - §1361. 401
Stock Option Plan Not "Second Class of Stock" - §1361. 403
Conversion Did Not Create Second Class of Stock - §1361. 405
S Corporation Status Retained After Charter Violation - §1362. 406
Circular Loans Did Not Increase S Shareholder's Basis - §1366. 407
C to S Conversion Requires Inventory Recapture - §1366. 408
Guarantee of S Corporate Debt Does Not Give Basis - §1366. 410
Loan Did Not Increase Stock Basis - §1366. 411
Selling Shareholder Treated as Continuing Owner - §1366. 412
Taxpayer Denied Deduction of S corporation Losses - §1366. 413
Mere Guarantee Give No Additional Basis - §1366. 414
Regs Adjust NUBIG in Carryover Basis Transactions - §1374. 415
Old S Elections Can’t Be Used to Avoid Built-in Gain - §1374. 417
Built-in Gains Exposure on Accounts Receivable - §1374. 419
Rental Activities Not Excess Passive Income - §1374. 420
Regs. on 10-Year Built-In Gains Period - §1374. 421
Co-op Payments Subject to S/E Tax - §1401. 422
Fishing Crew Member Was Self-Employed - §1401. 423
Co-op Payments Subject to S/E Tax - §1401. 424
Payments to Retired Partners Not Subject to SE - §1402. 425
Farm Rents Not Subject to SE - §1402. 426
Dealing with Regs on S/E Tax for LLC Members - §1402. 427
Farm Rents Not Subject to S/E Tax - §1402. 431
Payments to Disabled Salesman Subject to S/E Tax - §1402. 432
S Corporation President Determined to Be Employee - §3121. 433
Notice on Safe Harbor for Student FICA Exception - §3121. 435
Regs Clarifying Definitions for Student FICA Exception - §3121. 436
State Not Bound by Sec. 530 Relief - §3121. 436
Shareholder Who Received No Comp Held Employee - §3121. 437
Distributions Fail to Avoid Employment Taxes - §3121. 438
Penalties for Royalty Payments - §3121. 439
Tenure Buyouts Need Not Be Treated as Wages - §3121. 440
Partners Liable for Payroll Taxes for Up to 13 Years - §3401. 442
Signing Bonuses & Cancellation Payments Are Wages - §3401. 442
W-4s With More Than 10 Exemptions - §3401. 443
Final COBRA Notice Requirements - §4980B.. 444
No Reasonable Cause for Failure to Pay Estimated Tax - §6651. 446
Questionable Employment Tax Practices - §6672. 447
LLC Members Not Liable for LLC's Employment Taxes - §6672. 449
Nominee President Held Liable - §6672. 451
Casino General Manager Not Responsible Person - §6672. 452
CPA Was Not a Responsible Person - §6672. 453
Check Signing CPA Not Responsible Person - §6672. 455
Corporate Officer Liable for Trust Fund Penalty - §6672. 458
IRS Rules on Entity Classifications - §7701. 460
National Research Program (NRP) For S Corporations - Misc. 460
Fringe Benefits for Departing and Retiring Executives - Misc. 461
Technical Corrections for S Corporations - Misc. 464
Administrative Matters. 466
Controlled Group Research Credit Allocation Regs - §41. 466
IRS Properly Rejected AMT Compromise Offer on ISO - §56. 466
Couple Stuck With Stipulated Settlement - §61. 470
Real Property Tax Rebates & Tax Benefit Rule - §111. 470
Help for Combat Zone Military Personnel - §112. 473
Tax Relief for U.S. Military in Iraq - §112. 474
Restrictions for Tax-Exempt Bonds Regs - §148. 474
Guidance on Identifying Built-In Items - §382. 475
S Corporation Losses Belong to Bankruptcy Estate - §382. 476
Employee Plan Correction Guidance - §401. 477
Changes to Cash & Deferred Pension Plans - §401. 478
Plan Distributions Attributable to Rollover Amounts - §402. 479
Retroactive Plan Amendment Violates ERISA - §401. 480
Regs on Separate Treatment of Deemed IRAs - §408. 482
Final Regs on Calculating Recharacterized IRAs - §408. 483
Abusive Roth IRA Schemes - §408. 484
Regs on Deemed IRAs - §408. 485
Guidance Targets S Corp ESOP Abuses - §409. 487
Effect of Sale on Defined Benefit Plan - §410. 489
Payment of Plan Expenses Is Reasonable - §411. 490
Top Heavy Plan Definition - §416. 490
Retirement Benefit Value Comparisons Regs - §417. 491
Regs on Treatment of Statutory Stock Options - §422. 492
IRS Allows Spread of 'Short-Year' Income - §442. 492
Regs on Use of Nonaccrual-Experience Methods - §448. 494
IRS Resolves Partnership Accounting Issues - §460. 495
Payments Fail Economic Performance Test - §461. 495
Broker Denied Franchise Tax Deductions - §461. 497
Transfers to Satisfy Contested Liabilities - §461. 498
IRS Modifies Procedures for LIFO - §472. 500
Regs on Changes in Accounting Methods - §481. 501
Final Cost-Sharing Regs - §482. 502
'Simplified Method' Pricing Regs - §482. 503
Guidance on Expenditures for EO Advocacy Ads - §527. 503
Regs Target Use of Annuity Contracts - §817. 506
Bonds Deemed Investment in Government Securities - §851. 506
Mitigation Provisions Inapplicable - §1311. 507
Costs Don't Qualify for Special Rate Adjustment - §1341. 508
Foreign Partnership Withholding & Income - §1441. 508
Regs on Partnership Withholding - §1446. 509
Final Regs on Backup Withholding Procedures - §3406. 509
Relief from Employment Tax Liability - §3501. 510
Leased Back Held Prohibited Transaction - §4975. 511
Final Regs to Facilitate Electronic Return Filing - §6001. 513
Final Regs on Tax Shelter Reporting - §6011. 514
IRS Considers Discontinuing TeleFile - §6011. 515
Updated List of Tax Avoidance Transactions - §6011. 516
Regs on Electronic Filing by Businesses - §6011. 516
Abusive Foreign Tax Credit Transactions - §6011. 517
Abusive Transactions Involving S Corps - §6011. 518
Guidance on Tax Shelter Disclosure Penalties - §6011. 519
Spouse of Tax Evader Denied Relief - §6015. 521
Relief Procedures for Nonrequesting Spouse - §6015. 522
Spouse Denied Relief from Joint Liability - §6015. 522
Individual Entitled to Innocent Spouse Relief - §6015. 523
Executor May Pursue Innocent Spouse Relief - §6015. 525
Knowledge of Omission Denies Innocent-Spouse Relief - §6015. 525
Closing Agreement No Bar to Innocent Spouse Relief - §6015. 526
Corporate Secretary/Spouse Not Innocent Spouse - §6015. 527
No Innocent Spouse Relief before Effective Date - §6015. 528
Refund of Funds Levied From IRA - §6015. 529
Rules for Spouses Requesting Equitable Relief - §6015. 530
Request for Relief Untimely - §6015. 532
Equitable Spousal Relief Considered De Novo - §6015. 532
No Mutual Mistake Found - §6015. 534
Tax Lien Filed Before Final Determination Valid - §6015. 535
Nonelecting Spouse Allowed to Intervene - §6015. 536
No Relief for Knowledgeable Spouse - §6015. 537
Failure to Consider Innocent Spouse Relief Abuse - §6015. 538
Tax Court Lacks Jurisdiction after Bankruptcy - §6015. 539
Automatic Stay Bars Tax Court - §6015. 539
Innocent Spouse and "Override" Rule - §6015. 540
Spouse Permitted Innocent Spouse Relief - §6015. 541
Co-Working Spouse Granted Innocent Spouse Relief - §6015. 542
Husband Granted Relief Despite Reason to Know - §6015. 543
IRS Failed to Properly Inform Taxpayer of Rights - §6015. 543
Deception Justified Innocent Spouse Relief - §6015. 544
Community Property Beat Innocent Spouse Provisions - §6015. 546
Couple Liable for Taxes on Dummy Returns - §6020. 550
Guidance on Partnership Elections - §6031. 551
QFC Dividend Information Reporting - §6042. 552
Regs on Inversion Transaction Reporting - §6043. 552
Guidance on Substitute Payments - §6045. 553
Proposed Circular 230 Changes - §6060. 553
Rubber Stamp or Mechancial Signature OK - §6061. 554
Facsimile Signatures Allowed on Most Payroll Forms - §6061. 554
IRS Properly Withheld Documents §6103. 555
Gennifer Flowers's FOIA Request Dismissed - §6103. 556
Final Regs on Return Disclosure - §6109. 557
Notice Valid - §6212. 558
FPAA Valid Without Examining Partnership Return - §6212. 559
Attorney-Client Privilege Waived - §6226. 560
Tax Liens Have Priority Over Receiver's Lien - §6323. 561
Tax Liens Must Actually Be on File to Have Priority - §6323. 561
Partnership Transaction Not Cover for Tax Avoidance - §6225. 562
Small Partnership Exception to TEFRA - §6231. 563
Collection from Property Held in Tenancy by Entirety - §6321. 564
Escrowed Funds Aren't Tax Payment - §6330. 565
Decision to Proceed With Collection - §6330. 566
Couple Liable for Self-Employment Taxes - §6330. 567
Transferee Liability Sustained - §6330. 568
IRS Failed to Retain Lien Position - §6330. 569
Couple Allowed to Challenge Self-Assessed Tax - §6330. 570
Determination Notice Failure Doesn't Toll Statute - §6330. 571
Challenge to Accuracy of Self-Assessment Valid - §6330. 572
No Jurisdiction to Wage Levy - §6330. 573
No Benefit From IRS Agent’s Mistake - §6330. 574
Levy Enforcement Denied - §6331. 575
Quaker Group Liable for Employee's Taxes - §6332. 577
Regs on Property Exempt From Levy - §6334. 578
Individual Denied Refunds of Tax Overpayments - §6402. 579
Joint Overpayments in Community Property States - §6402. 580
Taxpayer Not Entitled to Keep Ex-Wife's Refund - §6402. 582
Refusal to Further Abate Interest Sustained - §6404. 584
Failure to Abate Interest Abuse of Discretion - §6404. 585
Tentative Refunds Were Rebate Refunds - §6411. 585
IRS Fails to Prove Fraud - §6501. 586
Deficiency Notices Timely as Filed - §6501. 587
Slavery Reparations Credit Refund - §6501. 588
Assessment of Partnership Employment Tax Timely - §6502. 588
Individual's Refund Claims Denied - §6511. 590
SOL Did Not Apply to Bar Refund - §6511. 591
Jurisdiction to Determine Overpayment Claims - §6512. 592
Refund Barred by Statute of Limitations - §6532. 594
No SOL for Erroneously Issued Tax Refund - §6532. 594
How to Make, Withdraw, or Identify Deposits - §6603. 596
Corporation Not Subject to Hot Interest - §6621. 598
Couple Not Estopped From Challenging Penalties - §6659. 599
Document Filed Late Not a Return - §6654. 600
Tighten Rules for Corporate Estimated Taxes - §6655. 602
Standards Updated for Avoiding Penalty Provisions - §6662. 603
Regs on Accuracy-Related Penalty Defenses - §6662. 603
Taxpayers Failed to Review Return - §6662. 604
Regulatory Definition of Adequate Disclosure - §6662. 605
Corporation Fraudulently Understated Income - §6663. 606
Final Regs on Circular 230 Standards - §6700. 607
Tax Evader's Taxes Not Dischargeable - §6871. 608
RAL Fees Aren't Avoidable Preferences - §6871. 608
Couple Denied Discharge of Taxes - §6871. 609
Returns Filed After IRS Assessment Qualify - §6871. 610
Tax Liabilities Not Discharged by Bankruptcy - §6873. 611
Surviving Corporation Subject to Transferee Liability - §6901. 612
Final OIC User Fee Regs - §7122. 613
Guidance on Submitting Compromise Offers - §7122. 613
Taxpayer Responsible for Determining Authority - §7122. 613
OIC Scams by Unscrupulous Promoters - §7122. 614
More OIC Scams by Unscrupulous Promoters - §7122. 614
Conviction for Filing False Tax Returns - §7206. 616
Disclosure Rules Require Consent for Outsourcing - §7216. 616
Foreclosure of Tax Liens OK - §7403. 620
Challenge of State Tax in Federal Court Not Barred - §7421. 621
Levy on Tenancy by the Entireties Is Proper - §7426. 623
Individual Fraudulently Conveyed Property - §7426. 624
Review of Jeopardy Assessment Untimely - §7429. 625
Petitioners Not Prevailing Party - §7430. 626
Petitioners Stuck With Bargained-for Settlement - §7430. 627
No Litigation Costs for Separate Litigation - §7430. 628
No Damages in Suit for Replacement Refund Check - §7433. 629
Income from an Erroneous Form 1099-INT - §7434. 630
IRS Fails to Prove Fraud - §7443A.. 630
IRS Doesn't Have to Produce Evidence - §7491. 632
Individual Entitled to Record Collection Hearing - §7521. 632
Tax Shelter Clients Get No Confidentiality - §7525. 634
Intervenors' Identities in Andersen Action Protected - §7525. 635
Denial of Motion to Quash - §7602. 636
Communication No Bar to Summons Enforcement - §7603. 637
IRS Investigates Real Estate - §7804. 638
Plans Don't Need to File Fringe Benefit Information - Misc. 640
List of Rulings No Longer Determinative - Misc. 641
Online Business Tools Site - Misc. 641
IRS Warns of Tax Avoidance Schemes - Misc. 641
Direct Seller Audit Technique Guide - Misc. 647
“Executive Stock Option” Settlement - Misc. 648
IRS Collects $3.7 Billion from Son of Boss - Misc. 648
Final Regs Concerning IRS Circular 230 - Misc. 650
Estate & Trust Matters. 652
Fees for Investment Advice Subject to 2% AGI Floor - §67. 652
Interest on Late Legacy Distribution Isn't Deductible §163. 652
IRA Isn't Completed Gift by Widow - §401. 653
Surviving Spouse May Roll Over IRA Distribution - §408. 654
Executor's Repayment Not Valid Rollover - §408. 655
Conservation Easement Not Charitable Contribution - §642. 655
Trust Allowed Share of Charitable Contribution - §642. 656
Regs Revising Definition of Trust Income - §643. 656
Regs on Election to Treat Trust as Part of an Estate - §645. 657
Settlor's Service as Trustee Won't Disqualify Trust - §664. 658
Gain Realized From Terminating Charitable Unitrust - §664. 659
Sample CRAT Instruments - §664. 659
One Measuring Life. 660
Term of Years Annuity Period. 660
Consecutive Interests for Two Measuring Lives. 660
Concurrent and Consecutive Interests. 661
Ordering Rules for Charitable Trust Distributions - §664. 661
Sample CRUT Documents - §664. 661
CRAT & CRUT Safe Harbor for Spousal Right of Election - §664. 664
Final Regs Explain Tax Character of CRT Distributions - §664. 665
Grantor Trust Tax Language Reduces Tax - §671. 668
Service Capitulates on Effort to AZero Out@ GRATs - §673. 671
Value of IRAs Not Discounted for Estate Tax - §691. 671
IRA Payments to Widow Are IRD - §691. 672
Beneficiaries Liable for Tax on IRD - §691. 673
Non-Compete Payments Held IRD - §691. 673
Portion of Annuity Value Ruled IRD - §691. 674
Accrued Interest on Inherited Savings Bonds Held IRD - §691. 675
Gift of Fractional Interest Held Sale - §1001. 676
Discounted Cash Flow Method Valuation - §2031. 677
No Discount for Marketability on Series E Bonds - §2031. 678
Valuation on Estate Tax Return Correct - §2031. 679
Value of Closely Held Stock in Estate - §2031. 680
Impact of Built-in Capital Gains Tax Limited - §2031. 681
Lottery Winnings Valued Using Annuity Tables - §2031. 683
IRA Cannot Be Discounted by Taxes Due - §2031. 684
Unlikely Events Allowed in Discounting Value of Stock - §2031. 685
Value Based on Stock Sale 14 Months After Death - §2031. 686
Discount for Built-in Capital Gain Tax Liability - §2031. 686
Buy-Sell Agreement Disregarded - §2031. 688
Undistributed Earnings Are Included Property - §2032. 689
Regs on Alternate Estate Valuation Date Elections - §2032. 691
Value of Improvements Included in Estate - §2033. 691
Portion of Settlement in Gross Estate - §2033. 693
Estate Must Include Gift Taxes Paid Within 3 Years - §2035. 694
Three Year Inclusion Rule - §2035. 696
GRAT Includable in Estate - §2036. 697
Partnership Contributions Includable in Gross Estate - §2036. 697
Property Contributed to Partnership Included in Estate - §2036. 699
Assets Includible in Gross Estate - §2036. 700
Estate Must Include Family Limited Partnership Assets - §2036. 701
Strangi Appellate Decision - §2036. 702
FLPs Failed to Keep Assets Out of Decedent’s Estate - §2036. 706
Successful Estate Planning With FLPs - §2036. 706
Property Transferred to FLP Includible in Estate - §2036. 713
Assets Transferred to FLP Includable in Estate - §2036. 714
FLP Assets Includable in Estate - §2036. 715
Retained Life Estate Denies Bona Fide Sale - §2036. 715
Bona Fide Sale Exception Absent in Transfer to FLP - §2036. 716
Transferred Residence Includible in Estate - §2036. 716
Decedent's One-Half of Residence Excludable - §2040. 718
Unexercised Power of Appointment - §2041. 719
Exercise of POA Has No Adverse Tax Consequence - §2041. 720
Widow Liable for Estate's Unpaid Taxes - §2053. 721
Executor's Fees Limited by Probate Estate Size - §2053. 722
Estate Awarded Litigation Costs - §2053. 723
Estate's Deduction for Exxon Claim Limited - §2053. 725
Estate Only Entitled to Limited Interest Deduction - §2053. 726
Interest Deductible on Loan Used to Pay Estate Taxes - §2053. 727
Interest Not Deductible As Administrative Expense - §2053. 728
Estate Entitled to Charitable Deduction - §2055. 729
No Deduction for Charitable Settlement - §2055. 730
Two Stock Classes Must Be Valued Together - §2056. 730
Estate Not Entitled to Marital Deduction - §2056. 731
Estate Can Adjust Value of QTIP Property - §2056. 732
Estate Denied Marital Deduction - §2056. 733
Deduction Decreased by Use of Assets to Pay Estate - §2056. 734
Widow's Interest Doesn't Qualify for Marital Deduction - §2056. 735
Non-Dividend Paying Stocks - §2056. 736
Disability Language Does Not Destroy QTIP Trust - §2056. 737
Interest Expense Not Necessarily Incurred - §2056. 738
Powers Insufficient to Qualify for Marital Deduction - §2056. 738
QTIP Election Extended to After-Discovered Asset - §2056. 742
Trust Eligible for Estate Tax Marital Deduction - §2056A.. 742
Charitable Deduction Limited - §2106. 743
Minority Discount on Indirect Gifts - §2501. 743
Gifts to QTIP Trust Completed Transfers - §2501. 745
Automatic "Resizing" of Gift Held Invalid - §2501. 746
Revised Form 709 - §2501. 746
Reciprocal Transfers Were Indirect Gifts - §2503. 747
Present versus Future Interest - §2503. 748
Annual Gift Tax Exclusion Goes to $12,000 in 2006 - §2503. 749
Prepayments of Tuition Not Taxable Gifts - §2503. 749
Gift Tax Savings Clause Void for Gift Tax Purposes - §2511. 750
Conveyance to Sons Incomplete Gift - §2511. 751
FLP Results in Indirect Gift - §2511. 751
Remainder Interest Includable in Estate's Income - §2518. 752
Disclaimer after Power of Appointment Not Qualified - §2518. 753
Beneficiary Can Disclaim IRA Balance - §2518. 755
Disclaimer Permitted After Withdrawals by Disclaimant - §2518. 757
Regs on Net Gift Lifetime Transfers of QTIP Interests - §2519. 760
Deduction for Present Value of Unitrust Amounts - §2522. 760
Gift to Charity Includes Only Economic Interests - §2522. 761
Regs on Deemed Allocation of Unused GST Exemption - §2632. 763
Method for Making Late Reverse QTIP Election - §2652. 764
Two-Life Annuity Interest in GRAT Is OK - §2702. 765
Sample Declaration of Trust for QPRT - §2702. 766
IRS Acquiescence to Walton Case - §2702. 767
Heirs Allowed to Inspect Decedent's Tax Returns - §6103. 769
Discretionary Installment Plan Denial - §6161. 770
Installment Payment of Estate Tax - §6166. 771
Taxpayer Liable as Transferee for Interest on Transfer - §6601. 771
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