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Table of Contents
June
2006

Note: In accordance with IRS Circular 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers before the Internal Revenue Service, the information on this website is not intended or written to be used as, and cannot be used as or considered to be a “covered opinion” or other written tax advice, and should not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein, for IRS audit, tax dispute or other purposes.

Asterisks indicate items in the Tax Clinic department.
 

Accounting Methods & Periods

  * IRS Clarifies Direct Labor Costs Cannot Be MSC
  *

UNICAP Errors, Omissions and Opportunities: TAM 200607021

 
Consolidated Returns
  *

Taxpayer Successful in Establishing No Successor

 
Estates, Trusts & Gifts
    AICPA Requests Guidance on Use of PTCs
    Tuition Prepayment by Donor Not Subject to Gift or GST Tax
     
Excise Taxes
  * Are Taxpayers Properly Paying the Federal Foreign Insurance Excise Tax?
     

Exempt Organizations

    IRS Outlines Prohibited Behavior for Charities during Political Election
 

Expenses

    Mixed Expense Reimbursements and Unreturned Overpayments Disqualified Entire Accountable Plan
     

Foreign Income & Taxpayers

* Interplay Between the Sec. 199 Manufacturing Deduction and the Sec. 965 Repatriation Provision
    Tax Accounting Issues for Foreign Trusts (Part I) by Lawrence H. McNamara
     

Gains & Losses

  * Variable Prepaid Forwards: Are Stock Loans Possible in Light of TAM 200604033?
     
Gross Income
    Allocation and Apportionment of Expenses for Sec. 199 Purposes by Margie Rollinson, Jill Schwieterman, Arlene Fitzpatrick and Vickie Kraay
     
Individuals
  *

IRS Tightens Vehicle Donation Rule

    Adoption Requirements Qualified as Unforeseen Circumstances for Principal Residence Exclusion
     
Interest Income & Expense
    Below-Market Loans May Have Unexpected Tax Results by Howard Godfrey, Robert Guinn and Edward Malmgren
     
LLCs and LLPs
    Reviewing LLC Documents for New or Existing Clients
     
Practice & Procedures
    IRS Warns Taxpayers against Frivolous Arguments
     
Practice Management
    Divesting Clients Wisely
     
Procedure & Administration
  * How Much Authority Do Revenue Rulings Have?
     
State & Local Taxes
    Will the Push for Origin-Based Sourcing Derail SST?
     
 
Reader Survey

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2006 AICPA