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Browse Beavers, James A.

1-127 out of 127 article(s)
Title Type Date Words
Lessee cannot take deduction for facade easement contribution. Nov 1, 2018 1356
Tax Court cannot determine overpayment in CDP review case. Nov 1, 2018 1191
Analysis of and reflections on recent cases and rulings. Mar 1, 2018 3643
Analysis of and reflections on recent cases and rulings. Sep 1, 2017 2623
Joint return not valid where one spouse filed separate return. Apr 1, 2017 1418
Failure to use S corporation correctly results in self-employment tax. Mar 1, 2017 1374
Tax Court takes a scalpel to surgeon's passive loss deductions. Mar 1, 2017 1816
Understatement of income not fraudulent. Aug 1, 2016 1724
Taxpayer wins big in transfer-pricing dispute. Aug 1, 2016 2673
Nevada must treat California agency like a Nevada agency in damages claim. Jul 1, 2016 1218
Potential expiration is not an event. Jul 1, 2016 1506
Scrappy taxpayer off the hook for self-employment taxes. Jun 1, 2016 1512
Post-death events taken into account in property valuation. Jun 1, 2016 1627
Executor not liable as fiduciary for unpaid estate tax. May 1, 2016 1750
Appeals court upholds Colorado use tax reporting law. May 1, 2016 1770
German who gave up U.S. residency liable for exit tax. Apr 1, 2016 1945
CDP notice of determination valid if actually received. Apr 1, 2016 975
Statutory language trumps tax policy. Mar 1, 2016 1282
Tax Court no help for opportunist girlfriend. Mar 1, 2016 1095
Stock received in demutualization has no basis. Feb 1, 2016 1413
IRS made "initial determination". Feb 1, 2016 954
Source of consideration for transfer not relevant in gift analysis. Jan 1, 2016 1519
Signing a return is still not optional. Jan 1, 2016 1482
Casual lender not allowed bad debt deduction. Dec 1, 2015 1525
Fifth Circuit: "taxpayer" means a person who pays tax. Dec 1, 2015 993
Government says obstruction; taxpayer says evasion. Nov 1, 2015 1451
Deduction for seized marijuana goes up in smoke. Oct 1, 2015 1236
Extension OK where individual had apparent authority to sign it. Oct 1, 2015 1301
Sterling Plan yields tarnished tax results. Sep 1, 2015 2122
Money can't buy love, but it can keep you out of prison. Sep 1, 2015 1124
Charitable deduction not allowed for conveyance of land preservation easement. Jul 1, 2015 2348
Maryland personal income tax regime violates Constitution. Jul 1, 2015 1807
Former shareholders held liable for corporate tax debt. Jun 1, 2015 2013
Gifts to trust qualify for annual exclusion. Jun 1, 2015 1444
Refunds of state credits are includible in income. May 1, 2015 1710
Supreme Court holds challenge to Colorado reporting requirements can go forward. May 1, 2015 1627
Payments to egg donor not excludable from income. Apr 1, 2015 1692
Taxpayer was a bona fide resident of U.S. Virgin Islands. Apr 1, 2015 1539
Analysis of and reflections on recent cases and rulings. Mar 1, 2015 2964
Assignment of rights in lawsuit results in capital gain. Feb 1, 2015 1425
Analysis of and reflections on recent cases and rulings. Nov 1, 2014 2264
Analysis of and reflections on recent cases and rulings. Sep 1, 2014 2522
IRS cannot enforce summons. Jul 1, 2014 1023
Analysis of and reflections on recent cases and rulings. Jun 1, 2014 2895
Taxpayer is not a real estate professional. May 1, 2014 1004
Earnout restriction causes substantial risk of forfeiture. Mar 1, 2014 2012
Taxpayer did not have fraudulent intent. Mar 1, 2014 1475
Valuation-misstatement penalty applies to tax shelter transactions. Feb 1, 2014 1449
Delegating authority does not allow taxpayer to avoid responsible person status. Jan 1, 2014 822
Isley and IRS Appeals cannot work it on out. Jan 1, 2014 1498
Gift determined with reference to assumption of potential estate tax liability. Dec 1, 2013 2376
IRS abused discretion by not considering taxpayer's offer-in-compromise. Dec 1, 2013 1326
Taxpayer in trade or business of being a "private attorney general". Oct 1, 2013 1909
Foreign citizen denied refund of erroneously withheld taxes. Oct 1, 2013 1012
Provision of services by corporation to shareholder not a constructive dividend. Sep 1, 2013 1053
Taxpayer not entitled to innocent spouse relief. Sep 1, 2013 1463
QSub status is not property of bankruptcy estate. Aug 1, 2013 1283
Loan guarantees were prohibited transactions that disqualified IRAs. Jul 1, 2013 1036
A closer look at the IRS's targeting of Tea Party and other groups for review. Jul 1, 2013 2064
Tax Court reverses its position on valuation misstatement penalty; Supreme Court agrees to hear case on the issue. Jun 1, 2013 1998
Tithing is not necessary expense. May 1, 2013 1565
Tax Court weighs in on STARS transaction. Apr 1, 2013 3154
Tax Court denies investment interest deduction. Mar 1, 2013 1600
Software license held to be intangible property right. Mar 1, 2013 1685
Payments to taxpayer held to be compensation, not distributions. Feb 1, 2013 1135
IRS not allowed to reclassify passive activity income. Feb 1, 2013 1479
Corporation sole cannot shelter pastor from tax trouble. Jan 1, 2013 749
Rehabilitation credits disallowed. Dec 1, 2012 1309
Tax Court cannot reopen whistleblower award claim. Dec 1, 2012 850
Supplemental unemployment compensation benefits not subject to FICA. Nov 1, 2012 1208
IRS Nonacquiesces to 47-year-old case. Nov 1, 2012 936
Taxpayers not insolvent for purposes of Sec. 108 exclusion. Oct 1, 2012 1011
Taxpayer liable for willful violation of FBAR requirements. Oct 1, 2012 1129
No deduction for donating right to burn house. Sep 1, 2012 985
Tax Court petition suspends limitation period. Sep 1, 2012 1682
Associated-property rule regulation held invalid. Aug 1, 2012 1470
Contributions increase shareholders' S corporation basis. Aug 1, 2012 754
Taxes from postpetition farm sale are not dischargeable. Jul 1, 2012 1039
Overstatement of basis does not extend assessment statute of limitation. Jul 1, 2012 1989
No deduction allowed for contribution of easement. Jun 1, 2012 873
Colorado notice and reporting requirements declared unconstitutional. Jun 1, 2012 1573
Qualified residence interest limits apply on a per residence basis. May 1, 2012 977
Filing false tax return leads to deportation charge. May 1, 2012 1300
Estimated amount of state income tax claim not deductible on estate tax return. Apr 1, 2012 1270
Banks are lenders to partnership, not partners. Mar 1, 2012 1242
ODC tax liability and audit information cannot be disclosed. Mar 1, 2012 1453
Exercise of stock options results in taxable income and compensation deduction. Feb 1, 2012 980
IRS nonacquiesces to Tax Court fraud holding. Feb 1, 2012 1305
Estate may deduct interest on loan between two trusts. Jan 1, 2012 1395
Corporation is "same taxpayer" for interest-netting purposes. Jan 1, 2012 1320
Tax trends: qui tam payment included in income tax return preparers win partial victory in fraudulent credit scheme case. Dec 1, 2011 1979
Taxpayer entitled to charitable deduction for gifts of L.L.C. units. Oct 1, 2011 2227
Charitable deduction allowed for expenses of cat rescue organization volunteer. Aug 1, 2011 1511
No reasonable cause for $3.4 million omission from income. Aug 1, 2011 1082
Request for accounting method change for prepaid expenses denied. Jul 1, 2011 1324
Memo addresses treatment of fraudulently altered returns. Jul 1, 2011 979
Expense does not qualify as compensation but does qualify as theft loss. Jun 1, 2011 1285
Lack of control does not except owners from trust fund recovery penalty. Jun 1, 2011 1066
Cooperative owner cannot deduct cooperative's casualty loss. May 1, 2011 845
Day-trading losses are dissipation of assets. May 1, 2011 680

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