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Unavailable Appraiser Results in High Taxes for Taxpayer

A taxpayer ended up owing a lot more taxes when his appraiser didn’t show up at his hearing.  In Estate of Tanenblatt v. Comm’r, the taxpayer contested the high value used by the IRS of an LLC of which he had a 16.667% interest.  The taxpayer attached a second … Continue reading

IRS Requests Public Comments on Stock Option and Purchase Plan Forms

The IRS has requested public comments on Form 3921 and Form 3922.  The forms cover stock options and purchase plans.  The comments are due by September 8, 2014.

See 79 FR 38671 (July 8, 2014).

Posted by David Song, Associate Editor, Wealth Strategies JournalContinue reading

IRS Requests Comments on Employment, Estate, and Trust Signature Forms

The IRS has requested public comments on Form 8455-EMP, Form 8453-FE, Form 8878-F, and Form 88790-MP.  The forms cover employment, estate, and trust signatures.  The comments are due by September 8, 2014.

See 79 FR 38670 (July 8, 2014).

Posted by David Song, Associate Editor, Wealth Strategies JournalContinue reading

Tax Court Holds Taxpayer Not Entitled to Innocent Spouse Relief

In a summary opinion, the Tax Court found that a taxpayer was not entitled to innocent spouse relief.  The IRS allows a a spouse, who files a joint income tax return, to be relieved from joint and several tax liability when it would be inequitable to hold the taxpayer liable … Continue reading

TD 9673: IRS Allows the Purchase of Longevity Annuities

The IRS issued final regulations regarding longevity annuity contracts.  The final rules modified minimum distribution rules to permit the purchase of longevity annuities.  Older retirement ages and longer life expectancies have lead to the real risk of running out of retirement funds.  The new final regulations allow longevity annuities which … Continue reading

Tax Court Finds Taxpayer Liable and Threatens Penalties for Frivolous Claims

The Tax Court held that a taxpayer was liable for unpaid taxes stemming from Social Security benefits and pension distributions and additions to tax for failing to to timely file a return.  The taxpayer argued that the IRS employee handling his case did not have proper authority to sign and … Continue reading

IRS Announces New Education Program for Tax Preparers

The IRS announced that there will be new voluntary program designed to encourage continuing education for tax return preparers.  The program would include a course in basic tax filing, ethics, and other federal tax law courses.  Unenrolled tax preparers will be able to obtain a record of completion after finishing … Continue reading

Second Circuit Affirms Denial of Charitable Deduction For an Easement

The Second Circuit affirmed a Tax Court decision stating that a taxpayer was not eligible for a charitable deduction for a conservation easement.  The taxpayer had donated a facade conservation easement to the National Architecture Trust.  However, the Tax Court ruled that the taxpayer was not eligible for a charitable … Continue reading

ESOPs Safe From Tax Reform

Senate Finance Committee member Pat Robers, R-Kan, stated that employee stock ownership plans (ESOPs) are fairly safe from tax reform.  He noted that people do not want to change a program that has been so successful.  Further, a bipartisan group introduced the Promotion and Expansion of Private Employee Ownership Act … Continue reading

OPR Warns Practitioners to Remove Circular 230 Disclaimers

The IRS Office of Professional Responsibility advised practitioners to stop using Circular 230 disclaimers.  The IRS finalized Circular 230 (T.D. 9668) replacing the covered opinion and establishing one standard for covered opinion rules.  The OPR warned that practitioners that include any disclaimers that state “The Internal Revenue Service says” or … Continue reading