Tiebreaker and IRS Flip Flop

IRS Changes Position on Claiming Childless EIC ( Earned Income Credit) Which means Amended Returns May be in Order The IRS issued proposed regulations which reflect a change in the IRS’s position on the interaction of the Code Sec. 152(c)(4) tiebreaker rules, which goes into effect when two or more people […]

When Goodwill Merges With Basis: Cost to IRS $206 Million

On October 31, 2016 a very interesting case  was decided  that cost IRS more than $206 Million . The crust of the issue was when does the Goodwill and Going Concerns, some of the most common intangible costs, become an inherent part of the basis. Section 1603 cases are always huge […]

Business or Hobby? Must Read

Here is an excellent example of when your “Business” is considered as Hobby by IRS and the disastrous results of this determination. In 2005, 2006, and 2007, Brent and Lynette McMinn operated a business which primarily involved acquiring used embroidery machinery, refurbishing it, and selling it. The McMinns would purchase and […]