tax Advice Archive
End of the Line for Paresky
May 3, 2021
No Comments
TweetShareSharePin0 Shares Guest blogger Bob Probasco returns today with perhaps his final update on the Paresky case. Christine Nothing about the decision was really surprising. The contrary decision in E.W. Scripps Co. v. United States, 420 F.3d 589 (6th Cir. 2005) was always a strained interpretation of the jurisdictional statutes, and the trend has been
Designated Orders, October 5 – 9, 2020
April 30, 2021
No Comments
TweetShareSharePin0 Shares Months ago, I heard an interview with the NYU Professor Scott Galloway about what the world may look like post-Covid. One of the main takeaways was to think of the pandemic not as a “change agent,” but rather as “accelerant” of trends that were already underway. I’d say this holds true with the
TEFRA + LCU = Confusion, Part 3
April 29, 2021
No Comments
TweetShareSharePin0 Shares In today’s post Bob Probasco concludes his three-part series on General Mills and the intersection of TEFRA and “hot interest.” Part One can be found here. Part Two, here. Christine In Part 1, I described the decision by the Court of the Appeals for the Federal Circuit in General Mills, Inc. v. United
TEFRA + LCU = Confusion, Part 2
April 28, 2021
No Comments
TweetShareSharePin0 Shares In Part Two of this three-part series, Bob Probasco examines the dissenting view in the recent General Mills case out of the Federal Circuit. Part One can be found here. Christine In Part 1, I described the decision by the Court of the Appeals for the Federal Circuit in General Mills, Inc. v.
TEFRA + LCU = Confusion, Part 1
April 27, 2021
No Comments
TweetShareSharePin0 Shares We welcome back guest blogger Bob Probasco for a three-part series inspired by the Federal Circuit’s recent 2-1 decision tossing General Mills’ refund claim as untimely under TEFRA, although the claim would have been timely under the standard timeframes of section 6511. Part 1 sets the stage and examines the majority’s reasoning. Christine
2021 child tax credit, EITC, and premium tax credit limits updated
April 26, 2021
No Comments
TweetShareSharePin0 Shares The IRS on Monday issued adjusted amounts for the child tax credit, the earned income tax credit (EITC), and the premium tax credit (PTC) for 2021, to reflect changes enacted in the American Rescue Plan Act of 2021, P.L. 117-2 (Rev. Proc. 2021-23). Only for tax years beginning in 2021, Section 9611 of
Who Will Complain About Pro-Taxpayer Ultra Vires Guidance?
April 26, 2021
No Comments
TweetShareSharePin0 Shares 0 Flares
Filament.io
Made with Flare More Info“>
0 Flares
×
In today’s post guest contributor Monte Jackel, Of Counsel, Leo Berwick, discusses IRS guidance that may be too taxpayer friendly. Les On April 22, 2021, the IRS issued Revenue Procedure 2021-20. This guidance obsoletes Rev. Proc. 2020-51 to
Taxpayer Cannot Avoid Penalties Even When Using Longtime Preparer
April 23, 2021
No Comments
TweetShareSharePin0 Shares I do not prepare tax returns. But I feel for the long-suffering preparers who try their best to get the information from clients to prepare an accurate tax return. For people with a variety of sources of income, like self-employed consultants with multiple clients, the process is burdensome—at least when compared to employees who
Expenses paid with 2020 PPP loans can be deducted on 2021 tax returns
April 23, 2021
No Comments
TweetShareSharePin0 Shares The IRS announced a safe harbor for certain businesses that received first-round Paycheck Protection Program (PPP) loans but did not deduct any of the original eligible expenses because they relied on guidance issued before the enactment of the Consolidated Appropriations Act, 2021 (CAA), P.L. 116-260, in December 2020. In Notice 2020-32 and Rev.
Late Submitted Erroneous Reimbursement Match
April 22, 2021
No Comments
TweetShareSharePin0 Shares In United States v. Page, No. 3:20-cv-08072 (D. Ariz. April 16, 2021) the court holds that a big wrong reimbursement the Internal Revenue Service sent out to the taxpayer can not be recouped due to the fact that the Division of Justice submitted the wrong reimbursement fit far too late. The concern of
