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Browse O'Driscoll, David

1-107 out of 107 article(s)
Title Type Date Words
Nonspouse beneficiary meets PPA '06 rollover requirements. Jul 1, 2007 679
Taxpayer liable for taxes misappropriated by payroll services firm. Jul 1, 2007 691
Auditor guidelines on business travel and meal per diems after Rev. Rul. 2006-56. Jun 1, 2007 598
Tax court capitalizes model home display costs. May 1, 2007 635
Non-CPA firm subject to PSC rate. May 1, 2007 665
Accrued payroll tax liability is deductible even if compensation is deferred under Sec. 404. Apr 1, 2007 778
Service modifies AOD on teachers' severance pay. Mar 1, 2007 544
Tax on emotional damages revisited: DC Cir. vacates Murphy. Mar 1, 2007 132
Clarifications. Correction notice Mar 1, 2007 82
IRS releases 2006 "adequate disclosure" guidelines. Jan 1, 2007 2189
2006 Arthur J. Dixon Award. Dec 1, 2006 150
Lessor of truck driver employees avoids 50% limit on per diems. Nov 1, 2006 1025
IRS changes procedures for equitable innocent spouse cases. Nov 1, 2006 692
Payments from neighborhood restoration program taxable. Oct 1, 2006 422
IRA valued without discount for anticipated tax liability. Aug 1, 2006 830
Adoption requirements qualified as unforeseen circumstances for principal residence exclusion. Jun 1, 2006 586
Sec. 403(b) annuity included in bankruptcy estate. May 1, 2006 677
Royalty from sale of interest in scholarly journal not taxable. May 1, 2006 816
Deficiency notice required for innocent spouse Tax Court petition. May 1, 2006 559
Seventh circuit upholds regulation on interest paid to related foreign persons. Apr 1, 2006 792
Sale of lottery payments produces ordinary income. Apr 1, 2006 674
Stock-purchase agreement and insurance proceeds disregarded in valuation of decedent's stock. Mar 1, 2006 829
Environmental remediation denied sec. 1341 relief again. Mar 1, 2006 764
Cooperative unit owner denied AMT property tax deduction. Feb 1, 2006 597
IRS releases 2005 guidelines for "adequate disclosure". Feb 1, 2006 1971
Tax court determines valuation discounts. Jan 1, 2006 834
Preparer penalties assessed on employer. Jan 1, 2006 719
MRAs and qualified profit-sharing plans. Dec 1, 2005 768
Equitable apportionment of estate tax deficiency. Dec 1, 2005 850
Employer has insurable interest in employees. Dec 1, 2005 951
Retiree coverage under medical reimbursement plan. Nov 1, 2005 745
Allocation of employee stock options to cost-sharing agreement. Nov 1, 2005 1329
Tool allowances must be based on actual cost. Nov 1, 2005 802
Self-constructed property eligible for simplified capitalization methods. Oct 1, 2005 941
Home office qualifies as residential rental property. Sep 1, 2005 551
Ninth Circuit reverses findings on reasonable compensation. Sep 1, 2005 481
Truckstops fail floor-space test for 15-year recovery period. Jul 1, 2005 804
HSA eligibility when spouse has non-HDHP family coverage. Jun 1, 2005 807
IRS guidance on reportable transaction disclosure penalties. Apr 1, 2005 935
IRS guidance on reportable transaction understatement penalties. Apr 1, 2005 1010
Penalty suspension period for amended returns. Apr 1, 2005 685
Rollover avoids RMDs. Mar 1, 2005 642
Supreme Court decides contingent fee cases. Mar 1, 2005 1453
Financial hardship defense to FICA and FUTA penalty. Mar 1, 2005 739
HRAs for former employees. Feb 1, 2005 622
IRS releases 2004 guidelines for "adequate disclosure". Feb 1, 2005 1487
Adequate notice of innocent spouse rights. Jan 1, 2005 737
Reimbursement of parking expenses. Jan 1, 2005 478
S status survives bankruptcy. Jan 1, 2005 757
IRS changes stance on debtors' pensions. Dec 1, 2004 679
Jobs credit reduces AMT wage deduction. Nov 1, 2004 696
FLP's full value included in estate. Nov 1, 2004 1096
Guidelines on withholding from compensation payments incident to divorce. Oct 1, 2004 871
Employee allowed itemized deduction for worthless loan to employer. Sep 1, 2004 555
Parent's president and chairman not liable for subsidiary's payroll tax. Sep 1, 2004 885
HSA eligibility for FSA and HRA participants. Jul 1, 2004 815
FLP transfers were bona fide. Jul 1, 2004 1378
Truckers' expense allowance subject to 50% deduction limit. Jul 1, 2004 1107
Safe harbor excludes HSAs from ERISA. Jun 1, 2004 706
Administrative expense deduction for interest on inheritance. Jun 1, 2004 575
Service intends to disallow theft loss deductions for declining stock prices. Jun 1, 2004 523
Service to update guidance on student FICA exception. May 1, 2004 659
Timing restrictions do not apply to distributions of rollover contributions. Apr 1, 2004 939
Environmental remediation costs ineligible for claim-of-right treatment. Apr 1, 2004 992
SESOP may repurchase stock distributed in IRA rollover. Apr 1, 2004 344
Courier can compute mileage allowance on same basis as compensation. Mar 1, 2004 1068
Second Circuit includes contingent fee award in client's income. Mar 1, 2004 1097
Separate liability requirements must be met prior to spouse's death. Mar 1, 2004 947
Private annuity not subject to OID provisions. Mar 1, 2004 589
Partnership retirement payments satisfy SE tax exemption. Mar 1, 2004 1116
IRS explains effect of bankruptcy on assessment SOL. Feb 1, 2004 777
IRA subdivided into trusts for each beneficiary satisfied RMD rules. Feb 1, 2004 733
Surviving spouse can roll over retirement plan left to deceased spouse's estate. Jan 1, 2004 717
Class action attorney fee award not includible in member's income or subject to withholding. Jan 1, 2004 648
IRS releases 2003 guidelines for "adequate disclosure". Jan 1, 2004 1234
Income from ISO exercise includible in AMTI on transfer of purchased shares. Dec 1, 2003 1234
REIT subsidiary may provide tenants with noncustomary services. Dec 1, 2003 799
Restricted lottery payments not valued under IRS actuarial tables. Nov 1, 2003 772
Insurance agency termination payments were ordinary income. Oct 1, 2003 794
Owners of multiple residences lose principal residence exclusion. Oct 1, 2003 865
Taxpayers have until Dec. 31, 2003 to elect out of mid-quarter convention for 2001. Sep 1, 2003 442
Bankruptcy professional fees are not SLLs for carryback purposes. Sep 1, 2003 986
Prearranged stock transfers qualify under Sec. 351. Aug 1, 2003 847
Software enhancements lacked requisite innovation and scientific experimentation for R&D credit. Aug 1, 2003 1035
15-year amortization for covenant not to compete in redemption acquisition. Aug 1, 2003 723
Refund claims involving a Saturday, Sunday or legal holiday. Aug 1, 2003 791
Trust's material participation not limited to trustee's activity. Jul 1, 2003 600
Late information returns do not preclude employee classification relief. Jul 1, 2003 1153
Revised procedures for relief from late S elections. Jul 1, 2003 1586
Nonrequesting spouse may seek administrative appeal of innocent spouse relief. Jun 1, 2003 489
Timely estimated tax payments can be based on late-filed returns. Jun 1, 2003 436
IRS consent not required for property classification change. May 1, 2003 844
Qualified annuity can be based on two lives . May 1, 2003 1274
Asbestos expenses are currently deductible. May 1, 2003 1031
Loss transactions exempt from tax shelter disclosure rules. May 1, 2003 858
Unpaid president of nonprofit organization was not responsible person. May 1, 2003 1480
Customer disputes and accrual of income. Mar 1, 2003 892
Interest capitalization issues under Sec. 263A(f). Mar 1, 2003 1186
Tax shelter lacked nontax business purpose. Mar 1, 2003 929
Worker classification of delivery person . Mar 1, 2003 663

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