must capitalize amounts paid to another party to defend or perfect title to intangible property if the other party challenges the taxpayer
's title to the intangible property.
For many years, the IRS clashed over the cash method of accounting with small business taxpayers
who provided services as the mainstay of their business but who were categorized as inventory resellers by the IRS because they provided some type of merchandise in addition to the services.
1058(a), if a taxpayer
transfers securities to a transferee pursuant to an agreement to return identical securities, the transferor recognizes no gain or loss on the exchange of the actual securities for the rights under the securities loan contract or on the later exchange of the rights under the securities loan contract for the actual securities.
examination team, if available, and the taxpayer
to list the computerized accounting records that will be the primary focus of the audit, i.e., general ledgers, accounts payable, and fixed
Failed to make the election because of intervening events beyond the taxpayer
Special basis rules apply if a taxpayer
receives a personal residence as a gift, bequest or payment for services rendered.
(c) electricity, natural gas, or potable water produced by the taxpayer
in the United States;
* Publicizing the taxpayer
advocate service, particularly among low-income groups.
Levies: The CAP can be used before or after a levy is made, before or after a seizure and, as with liens, can be used by nominees and third parties holding taxpayer
property (however, for a seizure, the appeal must be made within 10 business days after the Notice of Seizure is given to the taxpayer
).Thus, a third party in possession of a taxpayer
's property can use the CAP to challenge an IRS order to turn the property over to the Service to satisfy a claim against the taxpayer
Next, the QPP must have been MPGE "by the taxpayer
." (12) The roiling issue here has centered on the treatment of so-called contract manufacturers.
A forward exchange occurs when a taxpayer
sells the relinquished property, then later buys a replacement property within delayed exchange safe harbors, such as qualified intermediary and qualified escrow account [Treas.
An individual or business taxpayer
elects a section 1033 deferral simply by omitting a gain from its return for the year it realizes that gain as a result of an involuntary conversion.