The following are links to items mentioned in the Preparing Advanced 1040s course given in Riverside on October 23:
IRS’s New View on Acquisition Debt – Article describing CCA 200940030 where the IRS decided you could deduct interest on $100,000 of acquisition debt in excess of $1,000,000 as home equity debt.
IRS AMT Assistant – IRS page to help determine if taxpayer may be subject to AMT.
Bogus v. Commissioner – Tax Court decision this week that pointed out taxpayer should have kept records to support passive activity
Levels of Authority – article detailing the various authority levels under the regulations
FTB Position on TIC and Revenue Proc 2002-22 – FTB considers qualification under Revenue Procedure 2002-22 a minimum, but not necessarily standing alone sufficient, to qualify as an exchange of other than a partnership interest under §1031.
Garnett v. Commissioner, 132 TC No. 19, IRS loses on argument that LLC is by definition a limited partnership for §469 purposes
Hegarty v. Commissioner, TC Summary 2009-153, IRS loses the LLC argument again, this time with taxpayers representing themselves
Below is a Google Voice connect box. You can click on the button, provide your phone number, and Google will connect us toll free by calling you back and then, when you answer, calling me. The call is forwarded to me whereever I might be at the time. If I’m not available, you can leave a voice mail.
The following are links to items mentioned in the construction contracting course given for the Education Foundation on October 22, 2009 in Costa Mesa:
Below is a Google Voice connect box. You can click on the button, provide your phone number, and Google will connect us toll free by calling you back and then, when you answer, calling me. The call is forwarded to me whereever I might be at the time. If I’m not available, you can leave a voice mail.
I now have a Google voice number and will be testing out putting a “call me” widget on my posts here. For those of you who have come to earlier courses, I’m posting the widget here so that if you wish, you can try calling me on using the link. Note that it does not use your computer to place the call, but rather calls your phone and then connects the call.
Below is a Google Voice connect box. You can click on the button, provide your phone number, and Google will connect us toll free by calling you back and then, when you answer, calling me. The call is forwarded to me wherever I might be at the time. If I’m not available, you can leave a voice mail.
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):
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.
Malkin v. Commissioner – Taxpayer blows transfer tax planning due to both implied retained life estate and indirect gift on formation problems, among others.
Future presentations of this course offered by the Education Foundation: Santa Clara – September 21 Ventura – September 24 Los Angeles (LAX area) – September 25
