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By on January 27, 2022
In the Friday, January 20, 2023 edition of the Texas Register, the Texas Comptroller published yet an another set of proposed revisions to Texas Comptroller Rule 3.591, Franchise Tax Apportionment. See 48 Tex. Reg. 200 (Jan. 20, 2023).
Prevailing On Business vs. Hobby Determinations Is Now More Important Than Ever
By on January 20, 2023
Recently, Joel Crouch wrote an excellent blog about a taxpayer who prevailed over the IRS, which had argued that the taxpayer's ranching business was not really a business. While it is great that the taxpayer was victorious, had the Tax Court determined that the ranching operation was not a business, but a hobby, the taxpayer may have still been entitled to claim some deductions for its hobby expenses. This is, in part, because the years at issue in that case were 2015, 2016, and 2017. The legal landscape is much less friendly for recent years.
Tax Court Starts Off The Year Allowing the Deduction of Significant Losses from a Cattle Ranch
By on January 17, 2023
The U.S. Tax Court started off the year with a very nice win for taxpayers. In Wondries v. Commissioner, the court rejected the IRS's disallowance of loss deductions under IRC Section 183 and held that the taxpayers engaged in their cattle ranching activity for profit rather than as a hobby.
The IRS Compounding Interest Rate is 7%: Should You Make a Deposit or Advance Payment Now?
By on January 4, 2023
The IRS will charge interest on any amount of tax ultimately due. For taxpayers wanting to stop the accrual of interest before the liability is paid, some or all of the proposed deficiency can be deposited or paid to the IRS while the controversy continues.
UPDATE: SECURE 2.0: What You Need to Know
By on January 4, 2023
*UPDATE* President Biden has signed into law the 2023 Consolidated Appropriations Act.
To Rule or Not to Rule: IRS Updates for 2023 its No-Ruling Lists for Private Letter Rulings
By on January 3, 2023
Should you need either 100% tax certainty or the IRS to fix a past mistake, a private letter ruling may be the answer for you. There are areas, however, where the IRS will not issue a ruling. And for 2023, those areas have now been defined.