Editor: Mary Van Leuven, J.D., LL.M. Tax practitioners need a valid Form 2848, Power of Attorney and Declaration of Representative, to practice before the IRS on behalf of a taxpayer. Form 2848 allows ...

The Tax Court held that a Sec. 6662(b)(6) penalty and the increased rate for the penalty under Sec. 6662(i) applied to underpayments attributable to the disallowance of the taxpayers’ deductions from ...

The Fifth Circuit’s decision in Grigsby, 86 F.4th 602 (5th Cir. 2023), emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 credit. It ...

For years, the California Franchise Tax Board (FTB) has taken the position that trusts are subject to California state income tax on all of their California-source income, and that ...

Individuals are subject to two income tax systems: the regular income tax and the alternative minimum tax (AMT). Taxpayers must compute their tax under each system and pay the greater of the two ...

On occasion, taxpayers holding investments in foreign financial assets or with foreign financial institutions may find themselves in the uncomfortable position of realizing that they have failed to ...

The basic rule for when a partner recognizes gain as a result of a distribution is found in Sec. 731(a)(1), which applies to both current distributions (from current income and activities) and ...

Expenses are not tax deductible unless a specific provision in the Code allows their deduction. When an expense is connected with taxable income, taxpayers are highly motivated to find ways to deduct ...

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• The law known as the Tax Cuts and Jobs Act, P.L. 115-97, imposed a $10,000 limitation on individuals’ deduction of state and local taxes (SALT) for tax years 2018 through 2025. • In Notice 2020-75, ...

During the normal course of business, a taxpayer may find itself the recipient or payer of a settlement or judgment as a result of litigation or arbitration. The federal tax implications of a ...

Taxpayers generally must capitalize amounts paid to improve a unit of property. A unit of property is improved if the cost is made for (1) a betterment to the unit of property; (2) a restoration of ...