Description

This course discusses recent judicial and administrative tax decisions impacting corporations, pass-through entities, and individuals. A brief review of the judicial and administrative tax system includes a discussion of which court a taxpayer should use when an administrative remedy cannot be reached after an IRS audit.

A review of salient court cases includes the following topics:

• What is included in the definition of gross income, including Constructive Dividends, and Cancelation of Debt Income
• What is an activity engaged in for profit
• What is a “pre-opening” or “start-up” expense
• Limits on business expense deductions under IRC Sections 162, 274(d) and 262
• Limits on charitable contribution deductions
• Trust fund tax penalties, including determining who is a “responsible person” for paying federal employment taxes
• Tax credits, including the Energy and Research Credit and the Research and Development (R&D) credit
• Tax Administration issues including “innocent spouse” relief, relief from joint and several liability on a married filing jointly tax return, and reimbursement of reasonable litigation costs
• Tax penalties including the Foreign Bank and Financial Account (FBAR) reporting penalty, the accuracy-related penalty, the gross valuation misstatement penalty, and the fraud penalty

This course also discusses how to avoid/minimize common mistakes made when filing a tax return.