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Browse Fiore, Nicholas J.

1-112 out of 112 article(s)
Title Type Date Words
Prepaid services must be fully completed to use 3 1/2-month rule. Aug 1, 2007 887
Rules governing lodging away from home will be liberalized. Aug 1, 2007 404
Brother can claim EITC for younger siblings. (Credits Against Tax). Sep 1, 2002 616
S corporation holding company was not required to recapture share of LIFO reserves. Sep 1, 2002 732
Merger of pension plan into profit-sharing plan is not partial termination. Aug 1, 2002 1034
Single-member owners of disregarded LLCs should receive separate due process notices. Jul 1, 2002 1220
IRS discusses deductibility of underwriting fees. Jun 1, 2002 746
Mark-to-market election is not a disposition for PAL purposes. Jun 1, 2002 323
IRS suspends filing requirements for certain fringe-benefit plans. Jun 1, 2002 383
Airline costs allocable to vouchers issued are not deductible until vouchers are redeemed for tickets. (Expenses). May 1, 2002 1390
Costs of weight-loss program may be deductible. (Expenses). May 1, 2002 577
Husband's fraud will not toll limitations period for spouse's split-gift tax return. May 1, 2002 1180
IRS discusses possible prohibited transactions of redeemed shareholder. Apr 1, 2002 1714
Frequent-flyer miles attributable to business travel are not taxable. Apr 1, 2002 234
IRS guidance on failed Roth IRA conversion. Mar 1, 2002 675
IRS discusses documents on change in marital status. Mar 1, 2002 745
IRS discusses amount deductible for use of private plane. Feb 1, 2002 1143
Employer reimbursements to employees for salary-reduction amounts used to pay health insurance premiums were not excludible. Feb 1, 2002 831
IRS guidance on Gramm-Leach-Bliley Act and return preparers. Feb 1, 2002 159
Unsigned joint return was not valid; 10th Cir. reverses own decision and affirms Tax Court. Feb 1, 2002 736
Administrative expenses of bankruptcy estate are deductible from gross income. Jan 1, 2002 597
Real estate tax abatements under state senior citizen program were wages subject to FICA. Jan 1, 2002 1271
IRS releases 2001 guidelines for "adequate disclosure". Jan 1, 2002 1065
IRS issues guidance on relief from late allocation of GST exemption. (Estates, Trusts & Gifts). Dec 1, 2001 822
IRS issues guidance on exclusive provider arrangements and UBIT. (Exempt Organizations). Dec 1, 2001 655
IRS eases investment direction restriction for sec. 529 participants. (Individuals). Dec 1, 2001 547
IRA distributions based on joint life expectancies and AFR will be "substantially equal periodic payments". (Employee Benefits and Pensions). Nov 1, 2001 893
Valuation formula clause will not be respected for gift tax purposes. (Estates, Trusts & Gifts). Nov 1, 2001 1415
Nonelecting decedent's trust may challenge innocent-spouse relief to ex-wife. Nov 1, 2001 486
Form 1040 with all zeroes is not a valid return. (Procedures & Administration). Nov 1, 2001 991
IRS provides guidance on employee rental of home to employer. Oct 1, 2001 1251
Hand-written listing of assets was not qualified disclaimer. Sep 1, 2001 496
Construction allowance in lease agreements need not be for constructing or improving property to satisfy "purpose" requirement. Sep 1, 2001 721
S shareholder cannot offset self-charged management fees against nonpassive income. Sep 1, 2001 920
Partner in trader partnership may claim partnership's, operating expenses as trade or business expense. Aug 1, 2001 1805
IRS warns against frivolous filing positions that rely on foreign-based-income argument. Aug 1, 2001 533
Merger qualifies as tax-free reorganization, despite surviving corporation's immediate sale of assets. Jul 1, 2001 865
Executor may not elect innocent spouse relief on behalf of deceased spouse. Jul 1, 2001 1085
Value of decedent's unfinished residence, not completed value, was includible in gross estate. Jul 1, 2001 1159
Individuals may not deduct fees for credit cards used to pay personal income tax. Jun 1, 2001 938
Employment taxes assessed in SMLLC's name and EIN were valid assessments against company's sole owner. Jun 1, 2001 1195
"Pension" payments made by dissolved corporation in satisfaction of shareholder's alimony obligations were not deductible. May 1, 2001 1131
Portion of payment to former shareholder characterized as consulting expense had to be amortized. May 1, 2001 863
Nonmonetary recognition awards with $100 FMV were not de minimis fringe benefits. May 1, 2001 399
Puerto Rican resident was not subject to U.S. estate and gift taxes. May 1, 2001 643
IRS provides guidance on trust's sec. 645 election and short-year return. May 1, 2001 582
Unsigned return claiming joint filing status was valid; 10th Cir. reverses TC. May 1, 2001 912
Reimbursements to employees for parking at nontemporary work locations are excludible from wages. Apr 1, 2001 712
IRS issues guidelines on treatment of computer software. Mar 1, 2001 1203
Taxpayer who uses standard deduction may not use itemized deductions in computing AMT. Mar 1, 2001 393
IRS releases 2000 guidelines for "adequate disclosure". Mar 1, 2001 1117
IRS discusses financial status audit techniques. Mar 1, 2001 1251
Validly formed FLP was recognized for estate tax purposes. Jan 1, 2001 858
S Corporation holding company had to recapture pro rata share of LIFO reserves. Jan 1, 2001 1142
Suspended PALs from C years could be deducted in S election year. Jan 1, 2001 1311
S shareholder's personal guarantee did not allow for increased basis. Jan 1, 2001 809
S Corporation and C Corporation Cannot Aggregate Activities to Determine Profit Motive. Dec 1, 2000 1017
Guarantor Primarily Liable for Note Could Deduct Related Accrued Interest. Dec 1, 2000 418
Knowledge of Items Giving Rise to Understatement Precludes "Innocent Spouse" Relief. Dec 1, 2000 1598
Prepaid rent could not be deducted, absent substantial business reason for prepayment. Nov 1, 2000 356
IRS issues guidance on use of accommodation parties in deferred like-kind exchanges. Nov 1, 2000 1542
IRS provides guidance on corporate officer's work status classification. Nov 1, 2000 1465
Corporation that failed to provide accountant with sufficient information to prepare return was liable for accuracy-related penalties. Nov 1, 2000 272
Married taxpayer, filing as unmarried head of household, may use full standard deduction. Nov 1, 2000 913
Paving contractor was not required to use accrual method. Oct 1, 2000 794
Payments to nonqualified trust that replaced terminated pension plans were not exempt from employment taxes. Oct 1, 2000 1372
Extension of assessment period for certain foreign transfers applies only to required information, not entire return. Oct 1, 2000 997
Ex-spouse was entitled to intervene in "innocent spouse" suit. Oct 1, 2000 628
Travel expense reimbursements for assignments involving breaks in service at work locations. Sep 1, 2000 1620
Deduction for covenant not to compete allowed after accounting firm break-up. Aug 1, 2000 582
IRS Issues Guidance on Application of New Sec. 453(a)(2) to Installment Sales. Jun 1, 2000 1271
Estate was entitled to deductions for reimbursed gift taxes that heirs paid. Jun 1, 2000 1962
Employer's travel deduction not limited to amount reportable by employees. Jun 1, 2000 1393
Replacement Property Disposition after ESOP Sale Results in Recognition of Deferred Gain. Jun 1, 2000 1402
Personal Representative Who Relied on Attorney Was Not Liable for Estate's Unpaid Taxes. May 1, 2000 1263
Costs of Replacing Retired Assets Were Deductible. May 1, 2000 785
IRS Identifies "Tax-Avoidance" Transactions. May 1, 2000 438
Sup. Ct.: Valid Disclaimer of Inheritance Under State Law Could Not Avoid Federal Tax Liens. Apr 1, 2000 979
Payment Agreements with Acquiring Corporation May Be Golden Parachute Payments. Apr 1, 2000 775
Ownership of Home by Partnership Counts for Sec. 121 Purposes. Apr 1, 2000 852
"Reasonable cause" exception for failure to pay employment taxes requires examination of a taxpayer's total financial situation. Mar 1, 2000 2109
Seven-factor test for reasonable compensation was not valid. Jan 1, 2000 1732
IRS releases 1999 guidelines for "adequate disclosure". Jan 1, 2000 1117
IRS Provides Guidance on Special Partnership Allocations of COD Income. Dec 1, 1999 2250
Passive Loss Self-Rental Regulation Was Valid: 5th Cir. Affirms DC. Dec 1, 1999 619
Accuracy-Related Penalty Cannot Be Assessed Against Taxpayer Who Did Not File Valid Return. Dec 1, 1999 761
IRS Issues Guidance as to Interest on Overpayments and Subsequently Determined Deficiencies. Dec 1, 1999 2020
S Shareholders Not Entitled to Increase Bases by Guarantee of Corporate Debt. Dec 1, 1999 1153
Insolvent Estate's Personal Representative Was Liable for Disbursements Made, to Extent of Tax Liability Known. Nov 1, 1999 595
Bank's Mutual Fund Losses Were Not Ordinary Losses. Nov 1, 1999 512
Corporation's and Shareholder's Reasonable Reliance on Tax Adviser Precluded Negligence Penalty. Nov 1, 1999 347
Delay in Civil Case While Criminal Investigation Was Pending Was Not Ministerial Act. Nov 1, 1999 1297
Split-Dollar Insurance Transactions Will Not Give Rise to Charitable Deductions. Aug 1, 1999 1204
IRS Provides Procedures for Deferred Compensation. May 1, 1999 530
IRS Examines Effects of LILO Transactions. May 1, 1999 2101
IRS Provides Guidance on Waiver of Penalties for Certain EFT Deposits. May 1, 1999 750
RECENT CASES AND RULINGS. Dec 1, 1998 1809
Redemption Agreement Transferring Stock to Business Associate Was Not "Testamentary Device"; 2d Cir. Reverses TC. Nov 1, 1998 1803
IRS Explains Election to Defer Gain on Sale of QSB Stock. Nov 1, 1998 675
Regular tax and AMT NOLs subject to single carryback waiver election. Feb 1, 1992 1407

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