Tax Blog


Is Election to Waive NOL Carryback Irrevocable?

You have to be careful when electing to waive the right to carry back a net operating loss. This is particularly true if there are items on your tax returns from earlier years that the IRS may eventually adjust if …


Is Election to Waive NOL Carryback Irrevocable?

You have to be careful when electing to waive the right to carry back a net operating loss. This is particularly true if there are items on your tax returns from earlier years that the IRS may eventually adjust if audited. The Bea v. Commissioner, No. …


IRS Can Collect Father’s Tax Restitution from Son

The rules that allow the IRS to assess and collect criminal restitution as if it is a tax due present some unique questions.  In Bontrager v. Commissioner, 151 T.C. 12, the court considered whether the IRS can assess and collect a father’s t…


IRS Can Collect Father’s Tax Restitution from Son

The rules that allow the IRS to assess and collect criminal restitution as if it is a tax due present some unique questions.  In Bontrager v. Commissioner, 151 T.C. 12, the court considered whether the IRS can assess and collect …


IRS Appeals Guidance on In-Person Conferences

The IRS Office of Appeals has been making changes to how it conducts appeals conferences.  In this past few years, these changes have made it difficult to obtain an in-person conference.  The IRS recently issued interim guidance AP-08-1118-0013 to auth…


IRS Appeals Guidance on In-Person Conferences

The IRS Office of Appeals has been making changes to how it conducts appeals conferences.  In this past few years, these changes have made it difficult to obtain an in-person conference.  The IRS recently issued interim guidance AP-08-1118-0013 to auth…


The Dilemma: File A Timely or An Accurate Tax Return?

If you have an ongoing dispute with the IRS for one or more years and the outcome of that dispute will impact the current year, can you take a wait and see approach to filing the current year tax return?   The Namakain v. Commissioner, T.C. Memo. 2018-…


The Dilemma: File A Timely or An Accurate Tax Return?

If you have an ongoing dispute with the IRS for one or more years and the outcome of that dispute will impact the current year, can you take a wait and see approach to filing the current year tax return?  …


Court Clarifies Inventory Capitalization Rules for Producers

There are a few items that are low hanging fruit that make for easy adjustments for IRS auditors.  The adjustment for indirect costs is an example of such an adjustment that can be made for any taxpayer that has inventory.  …


Court Clarifies Inventory Capitalization Rules for Producers

There are a few items that are low hanging fruit that make for easy adjustments for IRS auditors.  The adjustment for indirect costs is an example of such an adjustment that can be made for any taxpayer that has inventory.  The recent Patients Mutual A…