IRS Installment Agreement Calculation Counts Spendthrift Trust Distributions

The IRS generally cannot reach funds in a spendthrift trust to satisfy the trust beneficiary’s unpaid tax debts.  But can the IRS factor in trust distributions in calculating the how much the taxpayer can pay ...
Read More

Donations to Pastor are Taxable Income, Not Gifts

The distinction between taxable compensation and non-taxable gifts comes up in a number of contexts and has led to a number of tax disputes.  Severance payments made to workers are an example.  The recent Felton ...
Read More

IRS Can Collect from Property Purchased in Corporation

Can a taxpayer put property beyond the IRS’s reach by purchasing the property in the name of a corporation or a third party?  The answer is typically “no.”  The recent Arlin Geophysical Co. v. United ...
Read More

Planning for Start-Up Businesses, Yacht Rental Example

New businesses may not be immediately profitable.  To help mitigate the financial risk, many businesses are started by workers who have a day job.  If the business is not immediately profitable it can help the ...
Read More

Family Member’s Mortgage Filing May Trump IRS Lien

If a child owes unpaid taxes to the IRS, can the parent file a lien against the child’s property to prevent the IRS from levying on the property?  The court considered this in United States ...
Read More

Income Earned by Child Taxed to Parent

If a minor child earns income, is the income taxable to the parent or the child?  There have been quite a few tax disputes involving this question.  The Ray v. Commissioner, T.C. Memo. 2018-160 court case ...
Read More

Conservation Easement Denied for Private Golf Course

Tax benefits can cause investors to put money were they otherwise would not.  The conservation easement is one example.  Conservation easements reward investors with charitable deductions for putting money into projects that conserve real property.  ...
Read More

Line of Credit Standby Fees, to Deduct or to Capitalize?

Many businesses rely on a standby line of credit to cover their expenses, to weather downturns, and to grow.  But this credit can be expensive in terms of interest and fees. The fees can be ...
Read More

Court Says Partnership is Worth Less, Not Entirely Worthless

The IRS often challenges tax loss deductions.  In many cases, it does so by challenging the year in which the loss is allowable.  It can be difficult to determine which year the loss should be ...
Read More

IRS Audits for Car & Truck Expenses, What You Need to Know

There are a number of issues that the IRS frequently examines on audit.  Car and truck expenses are high on that list.  The applicable rules and court cases must be reviewed before presenting records to ...
Read More