In Carter v. Commissioner, the Tax Court upheld the disallowance of charitable contribution deductions for the conveyance of an easement to a qualified organization. The opinion synopsis is as follows: DH, a partnership of which Ps were partners, conveyed to NALT, a "qualified organization" within the meaning of I.R.C. sec. 170(h)(3), an easement that restricts … Continue reading Carter v. Commissioner, T.C. Memo 2020-21: Married Individuals Denied Charitable Contribution Deductions; Supervisory Approval Not Met
The IRS has published a tax practice unit on the determination of a tax home for purposes of Code Section 911, dealing with US citizens or residents living abroad. The summary is as follows: This Unit supersedes the 12/15/14 Unit with the same title. This Unit discusses the factors to be considered in determining an … Continue reading IRS Tax Practice Unit on Tax Home for Purposes of IRC Section 911
The IRS has published a tax practice unit on source of income for nonresident aliens. The summary is as follows: NOTE: This Practice Unit was updated to incorporate changes due to the Tax Cuts and Jobs Act for tax years beginning after 12/31/2017 and supersedes the 05/12/16 Unit with the same title. Source of income … Continue reading IRS Tax Practice Unit on Source of Income for Nonresident Alien Individuals
In Information Letter 2019-0029 the IRS ruled that a testamentary transfer of Series EE Bonds to a trust is taxable event. The contents of Information Letter 2019-0029 is as follows: This letter responds to your letter dated July 30, 2019, in which you requested information on the federal income tax consequences of the testamentary transfer … Continue reading Information Letter 2019-0029: Testamentary Transfer of Series EE Bonds to Trust is Taxable Event
In IR-2020-6, the IRS announced its free file program. It's announcement reads as follows: Most taxpayers can get an early start on their federal tax returns as IRS Free File – featuring brand-name online tax providers − opens today at IRS.gov/freefile for the 2020 tax filing season. Taxpayers whose adjusted gross income was $69,000 or less in 2019 – … Continue reading IRS Launches Free File (Jan. 13, 2020)
The IRS has updated its Audit Techniques Guide that addresses excise tax on structured settlement factoring transactions. Audit Guides focus on developing highly trained examiners for particular market segments by presenting examination techniques, common and unique industry issues, business practices, industry terminology and other information. To see the updated Structured Settlement Audit Guide click here.
The IRS has updated its Audit Techniques Guide that addresses the tax consequences for real estate property that is disposed of through foreclosure, short sale, deed in lieu of foreclosure and abandonments. Audit Guides focus on developing highly trained examiners for particular market segments by presenting examination techniques, common and unique industry issues, business practices, … Continue reading IRS: Updated Audit Techniques Guide: Real Estate Foreclosures, Short Sales and Cancellation of Debt