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
In October, 2016, the Internal Revenue Service issued temporary and proposed regulations under Inter...
Whether income earned by an incorporated personal service business is taxable to the individual or t...
In response to widespread concern that many taxpayers were renting their vacation homes in order to ...
When a taxpayer sells property and receives a purchaser\u27s obligation in exchange, the Internal Re...
Incorporation of an existing business almost invariably raises the question of whether the corporati...
The language of the Internal Revenue Code is subject to continuous interpretation by courts and admi...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
The 1983 U.S. Supreme Court decision in Commissioner v Tufts established the modern rule that requir...
This installment closes a loop begun in the last installment of this column. We have been exploring ...
This comment will consider the extent to which a taxpayer must, because he received written evidence...
Differences between tax accounting rules and generally accepted accounting principles have been a so...
The publication of Revenue Ruling 70-239 creates concern with respect to the possible impact of the ...
In the early 1980\u27s, Congress faced the mounting problems of tax shelters and other forms of tax ...
Prior to his retirement as a general agent of a life insurance company, the petitioner entered into ...
After the recent presidential election, Section 1043 of the Internal Revenue Code has received both ...
In October, 2016, the Internal Revenue Service issued temporary and proposed regulations under Inter...
Whether income earned by an incorporated personal service business is taxable to the individual or t...
In response to widespread concern that many taxpayers were renting their vacation homes in order to ...
When a taxpayer sells property and receives a purchaser\u27s obligation in exchange, the Internal Re...
Incorporation of an existing business almost invariably raises the question of whether the corporati...
The language of the Internal Revenue Code is subject to continuous interpretation by courts and admi...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
The 1983 U.S. Supreme Court decision in Commissioner v Tufts established the modern rule that requir...
This installment closes a loop begun in the last installment of this column. We have been exploring ...
This comment will consider the extent to which a taxpayer must, because he received written evidence...
Differences between tax accounting rules and generally accepted accounting principles have been a so...
The publication of Revenue Ruling 70-239 creates concern with respect to the possible impact of the ...
In the early 1980\u27s, Congress faced the mounting problems of tax shelters and other forms of tax ...
Prior to his retirement as a general agent of a life insurance company, the petitioner entered into ...
After the recent presidential election, Section 1043 of the Internal Revenue Code has received both ...
In October, 2016, the Internal Revenue Service issued temporary and proposed regulations under Inter...
Whether income earned by an incorporated personal service business is taxable to the individual or t...
In response to widespread concern that many taxpayers were renting their vacation homes in order to ...