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Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

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By Joel N. Crouch on February 7, 2023

What Do The National Taxpayer Advocate and David Letterman Have In Common?... [ read ]

When I was in college, Late Night With David Letterman, which was on NBC immediately after The Tonight Show With Johnny Carson, was must see TV. I know I am dating myself, but almost every weeknight my fraternity brothers and I would watch Late Night to see Dave, Paul Schafer, Larry "Bud" Melman, stupid pet tricks, stupid people tricks, the guy under the seats and other wacky bits. Of course, this was only after we had completed 2-3 hours of quality study time at the fraternity house. I know from recent experience that you can waste a whole weekend watching old Late Night clips on YouTube, including an audience favorite, the nightly Top 10 list. The Top 10 list was usually topical, but could be anything.

By David E. Colmenero on January 27, 2022

Proposed Revisions to Texas Comptroller Rule 3.591 (Apportionment) Seek to Incorporate the Texas Supreme Court's Holding in Sirius XM Radio, Inc.... [ read ]

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).

By Jeffrey M. Glassman on January 20, 2023

Prevailing On Business vs. Hobby Determinations Is Now More Important Than Ever... [ read ]

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.

By Joel N. Crouch on January 17, 2023

Tax Court Starts Off The Year Allowing the Deduction of Significant Losses from a Cattle Ranch... [ read ]

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.

By Josh O. Ungerman on January 4, 2023

The IRS Compounding Interest Rate is 7%: Should You Make a Deposit or Advance Payment Now?... [ read ]

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.

By Jana L. Simons on January 4, 2023

UPDATE: SECURE 2.0: What You Need to Know... [ read ]

*UPDATE* President Biden has signed into law the 2023 Consolidated Appropriations Act.

By Anthony P. Daddino on January 3, 2023

To Rule or Not to Rule: IRS Updates for 2023 its No-Ruling Lists for Private Letter Rulings... [ read ]

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.

By Jana L. Simons on December 29, 2022

SECURE 2.0: What You Need to Know... [ read ]

Just three short years after the passage of some of the most significant changes to the U.S. retirement saving and funding system in the form of the SECURE Act, Congress has passed "SECURE 2.0" as part of the recent spending package, the 2023 Consolidated Appropriations Act, with Division T covering SECURE 2.0, a Senate Finance Committee summary. The Omnibus Bill is expected to be signed into law by President Biden ahead of the December 30th government funding deadline.

By Joel N. Crouch on December 19, 2022

The Hidden Dangers of Filing a Tax Court Petition, Part III... [ read ]

I've previously written two blog posts regarding the "hidden" dangers of filing a Tax Court petition. In both blog posts, I discussed taxpayers who received Notices of Deficiency, filed Tax Court petitions and were surprised by the IRS answer, wherein the IRS increased the stakes by proposing a 75% fraud penalty for the first time.

By Joel N. Crouch on December 5, 2022

IRS Exam Training Materials on Employee Retention Credit... [ read ]

In a prior blog post, I discussed the IRS warnings about Employee Retention Credit (ERC) abuse and the IRS training more than 300 auditors and criminal investigators to examine claims involving the ERC. According to IRS officials, the auditors and criminal investigators have now all completed a 56-hour training course on ERCs.