09.21.09
Partnership Taxation Advanced Issues – September 21, 24-25, 2009
The following items were discussed in the Partnership Taxation Advanced Issues course presented for the Education Foundation on September 21 (Santa Clara), 24 (Ventura) and 25 (Los Angeles):
- Partnership – Audit Technique Guide – IRS guide last revised in August 2008
- FTB Position on TIC and Revenue Proc 2002-22 – FTB considers qualification under Revenue Procedure 2002-22 a minimum, but not necessarily in its self-sufficient, to qualify as an exchange of other than a partnership interest.
- Norwood v. Commissioner, TC Memo 2000-84
- Garnett v. Commissioner, 132 TC No. 19, LLC members aren’t automatically passive (LLC member not the same as limited partner)
- Revised Procedure for Late Entity Selection – revised manual pages on new late election Revenue Procedure effective September 28, 2009.
- Article on Partnerships and §6501(e) Six Year Statute – article I wrote for the Arizona Society of CPAs blog site.
- IRS FAQ on Unified Partnership Audits – Chief Counsel Notice issued August 21, 2009
- Suzanne J. Pierre v. Commissioner– Check the box does not apply to single member LLC for gift tax valuation
- Malkin v. Commissioner – Taxpayer blows transfer tax planning due to both implied retained life estate and indirect gift on formation problems, among others.
- TaxTalk Discussion Group – California Society sponsored
- Presentation Slides – PDF format file
- My Twitter Feed – my Twitter name is edzollars
- IRS Release on Extension of Offshore Program – the breaking news of the morning of the Santa Clara course
