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In field attorney advice memo 20121602F, the IRS determined that the "all-events test", which determines when a liability is incurred and deductible, is met when a wholesaler sells products to a pharmaceutical company at prices below the wholesaler's acquisition...
In an Action On Decision (AOD), the IRS announced that it will acquiesce, in the result only of a decision in which the U.S. District Court held that a decedent's estate was entitled to a refund of deficiency assessed on contingent bequests. An AOD is a formal...
If you owe back taxes to the IRS, then the IRS has the power to garnish your wages, impose liens on your property and even seize your assets. One method the IRS uses to accomplish this is through a federal tax lien. Filed with the local county courthouse, a federal...
As California residents prepare to file their taxes, there is one thing that tax officials are concentrating particularly hard on: sales taxes on items purchased online. Under state law, California residents must pay a "use tax" on any goods purchased online from a...
IRS Notice CC-2012-008 announces new Chief Counsel Coordination Procedures for asserting the economic substance doctrine, which was recently codified in Internal Revenue Code Section 7701(o). The notice is intended to ensure that the economic substance doctrine is...
Internal Revenue Service (IRS) commissioner, Douglas Shulman, said he doesn't intend to stay in the job after his five-year term expires in November. "My plan is to leave at the end of my term," he said during a question-and-answer session today at the National Press...
Perhaps unsurprisingly to many California residents, the IRS has recently stepped up its efforts with regard to audits of the wealthiest Americans. The largest increase was for those taxpayers who make more than $10 million per year, although significant increases...
In a recently released legal memorandum, the Internal Revenue Service (IRS) ruled that taxpayers' losses resulting from investments in funds that were used to operate a Ponzi scheme are theft losses under § 165, even though the taxpayers invested through...
The IRS has published the new 2011 Data Book, which is available here. The book contains various interesting statistics relating to the IRS's criminal investigation function.Table 18, Criminal Investigation Program, by Status or Disposition, Fiscal Year 2011 is...
The IRS just announced penalty relief for any farmers who had to file their return after March 1 due to delays associated with the MF Global bankruptcy case. This new release indicates the magnitude and far-reaching implications associated with untangling MF Global's...
