Add to ORKGWhen a taxpayer sells property and receives a purchaser\u27s obligation in exchange, the Internal Revenue Service\u27s new reporting rules for cash and accrual basis taxpayers result in inconsistent applications of section 1001(b) of the Internal Revenue Code. In Revenue Ruling 79-292, the Service treats section 1001(b) as being modified by section 451\u27s method of accounting rules, this position subsequently has been incorporated into the temporary regulations under the Installment Sales Revision Act of 1980. The author argues that section 1001(b) operates independently of a taxpayer\u27s method of accounting and that the Service\u27s position creates doctrinal disharmony in the area of deferred reporting
This installment closes a loop begun in the last installment of this column. We have been exploring ...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
In United States v. Carlton, the Supreme Court rejected a Due Process challenge to the retroactive e...
When a taxpayer sells property and receives a purchaser\u27s obligation in exchange, the Internal Re...
This comment will consider the extent to which a taxpayer must, because he received written evidence...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
During 1953, petitioner sold her farm and agreed to receive payment in yearly installments. Her 1953...
Differences between tax accounting rules and generally accepted accounting principles have been a so...
Prior to his retirement as a general agent of a life insurance company, the petitioner entered into ...
The 1983 U.S. Supreme Court decision in Commissioner v Tufts established the modern rule that requir...
Incorporation of an existing business almost invariably raises the question of whether the corporati...
In 1984, Congress enacted Internal Revenue Code section 132 to bring more certainty to the taxation ...
In October, 2016, the Internal Revenue Service issued temporary and proposed regulations under Inter...
In Estate of McKelvey v. Commissioner, the Second Circuit Court of Appeals adopted the IRS’s positio...
In the early 1980\u27s, Congress faced the mounting problems of tax shelters and other forms of tax ...
This installment closes a loop begun in the last installment of this column. We have been exploring ...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
In United States v. Carlton, the Supreme Court rejected a Due Process challenge to the retroactive e...
When a taxpayer sells property and receives a purchaser\u27s obligation in exchange, the Internal Re...
This comment will consider the extent to which a taxpayer must, because he received written evidence...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
During 1953, petitioner sold her farm and agreed to receive payment in yearly installments. Her 1953...
Differences between tax accounting rules and generally accepted accounting principles have been a so...
Prior to his retirement as a general agent of a life insurance company, the petitioner entered into ...
The 1983 U.S. Supreme Court decision in Commissioner v Tufts established the modern rule that requir...
Incorporation of an existing business almost invariably raises the question of whether the corporati...
In 1984, Congress enacted Internal Revenue Code section 132 to bring more certainty to the taxation ...
In October, 2016, the Internal Revenue Service issued temporary and proposed regulations under Inter...
In Estate of McKelvey v. Commissioner, the Second Circuit Court of Appeals adopted the IRS’s positio...
In the early 1980\u27s, Congress faced the mounting problems of tax shelters and other forms of tax ...
This installment closes a loop begun in the last installment of this column. We have been exploring ...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
In United States v. Carlton, the Supreme Court rejected a Due Process challenge to the retroactive e...