Vines, 126 TC 279 (2006), the Tax Court ruled that a taxpayer
who lost over $25 million from trading securities could be allowed an extension to take a Sec.
can use it every two years, as long as they've met both the required conditions.
To be consistent, the Notice should permit gross receipts derived from leases and rentals of real property to be included in DPGR along with sales receipts or, alternatively, should limit the application of this provision to those taxpayers
being compensated for physically constructing real property.
In designating replacement property, there appear to be three guidelines CPAs can advise taxpayers
used the dollar-value, inventory price index computation (IPIC) LIFO method.
must capitalize the costs of prepaid expenses, such as prepaid insurance and prepaid rent.
in the trade or business of farming are excluded from using this notice.
Until the government issues guidance that addresses some of the issues raised by TAM 200604033, taxpayers
will be left wondering whether their existingVPFs and stock loans "work" and whether stock loans should be avoided altogether when entering into future VPFs.
Many CIC taxpayers
use enterprise resource planning (ERP) systems such as those offered by Oracle, PeopleSoft, and SAP.
The program minimizes the contentious environment that often exists between the taxpayer
and the IRS during an audit.
The shrinkback rule offers additional opportunities for taxpayers
to qualify more of their receipts as DPGR.
An Offer in Compromise is an agreement between a taxpayer
and the IRS that resolves the taxpayer