LLC Owned by Self Directed IRA Cannot Pay Wages

The U.S. Court of Appeals for the Eleventh Circuit recently affirmed Ellis v. Commissioner, which held that the payment of wages for services to a self-directed IRA owner for his services rendered to an LLC owned by a self-directed IRA …..

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Offer in Compromise based on Doubt as to Liability Rejected for Cancellation of Debt Income

In Wyatt v. Commissioner, T.C. Summary Opinion 2015-31, the U.S. Tax Court rejected the taxpayer’s offer in compromise based on doubt as to liability for cancellation of debt income. The facts and procedural history are as follows: Dr. Wyatt was …..

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Reasonable Cause Defense for Penalty Waives Privilege

In Eaton Corporation & Subsidiaries v. Commissioner, the U.S. Tax Court concluded that raising the reasonable cause/good faith defense to tax penalties waived the work product, attorney-client, and federal tax practitioner privileges. Eaton had entered into Advance Pricing Agreements (“APAs”) …..

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Truck Stop Electrification Expenses Deductible, But Travel Expenses and Traffic Ticket Are Not

In Howard v. Commissioner, T.C. Memo. 2015-38, the U.S. Tax Court concluded that truck stop electrification expenses were deductible, but travel expenses and a traffic ticket were not deductible. The facts and procedural history are as follows: Mr. Howard was …..

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Bartender Tip Income Substantiated by Taxpayer Records

In Sabolic v. Commissioner, T.C. Memo. 2015-32, the U.S. Tax Court found that a bartender’s daily tip records were sufficient to establish the amount of his tip income even when the bartender opted out of the IRS’s Gaming Industry Tip …..

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Over-the-Road Truck Driver Not Entitled to Deduct Travel Expenses

In Jacobs v. Commissioner, T.C. Summary Opinion 2015-3, the U.S. Tax Court concluded that an over-the-road truck driver was not entitled to deduct travel expenses for traveling away from home since he lived in his truck. The facts and procedural …..

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Joint Committee Review Limit Increased to $5 Million

The Joint Committee on Taxation or JCT is a part of the U.S. Congress. It is tasked with investigating the U.S. tax system and reporting on proposed measures and methods for the simplification of taxes. To carry out this function, …..

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