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We Have The Receipts


1 Battle Camp: Final 5 Episodes with Dana Moon + Interview with the Winner! 1:03:29
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Finally, we find out who is unbeatable, unhateable, and unbreakable in the final five episodes of Battle Camp Season One. Host Chris Burns is joined by the multi-talented comedian Dana Moon to relive the cockroach mac & cheese, Trey’s drag debut, and the final wheel spin. The Season One Winner joins Chris to debrief on strategy and dish on game play. Leave us a voice message at www.speakpipe.com/WeHaveTheReceipts Text us at (929) 487-3621 DM Chris @FatCarrieBradshaw on Instagram Follow We Have The Receipts wherever you listen, so you never miss an episode. Listen to more from Netflix Podcasts.…
2025-03-17 IRS Guidance on When a Scam Generates a Theft Deduction
Manage episode 471719975 series 16567
Content provided by The Ohio Society of CPAs. All podcast content including episodes, graphics, and podcast descriptions are uploaded and provided directly by The Ohio Society of CPAs or their podcast platform partner. If you believe someone is using your copyrighted work without your permission, you can follow the process outlined here https://ppacc.player.fm/legal.
This week we look at:
- Tax Court Finds Taxpayer Failed to Provide a Qualified Appraisal, No Charitable Deduction Allowed
- Estate Found Liable for $2 Million FBAR Penalty That Applied to the Decedent
- Taxpayers Filing Court Challenges to Attempt to Obtain Employee Retention Tax Credits
- Fourth Circuit Overturns Trial Court’s Grant of Summary Judgment to the Government, Finding True Issue of Fact Exists Regarding Whether Statute Remained Open
- IRS Memorandum Discusses When a Taxpayer Can Claim a Deduction as Victims of Various Scams Under Current Law
213 episodes
Manage episode 471719975 series 16567
Content provided by The Ohio Society of CPAs. All podcast content including episodes, graphics, and podcast descriptions are uploaded and provided directly by The Ohio Society of CPAs or their podcast platform partner. If you believe someone is using your copyrighted work without your permission, you can follow the process outlined here https://ppacc.player.fm/legal.
This week we look at:
- Tax Court Finds Taxpayer Failed to Provide a Qualified Appraisal, No Charitable Deduction Allowed
- Estate Found Liable for $2 Million FBAR Penalty That Applied to the Decedent
- Taxpayers Filing Court Challenges to Attempt to Obtain Employee Retention Tax Credits
- Fourth Circuit Overturns Trial Court’s Grant of Summary Judgment to the Government, Finding True Issue of Fact Exists Regarding Whether Statute Remained Open
- IRS Memorandum Discusses When a Taxpayer Can Claim a Deduction as Victims of Various Scams Under Current Law
213 episodes
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1 2025-05-12 Taxpayer Fails to Qualify for Deduction for DoD Ordered Move 1:19:22
1:19:22
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This week we look at: Deductibility of IVF and Gestational Surrogacy Costs Fraudulent Tax Claims & 28 U.S.C. § 2514 Tax Collection Suits & Statute of Limitations in United States v. Ragen Moving Expense Deduction - Civilian Department of Defense Contractor Eligibility Tax Court Jurisdiction - The 90-Day Deadline for Deficiency Petitions…

1 2025-04-28 Twice to the Supreme Court 1:06:50
1:06:50
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This week we look at: Navigating the Overlap: Civil Tax Assessments and Criminal Restitution Orders Navigating Innocent Spouse Relief: A Look at Salvi v. Commissioner Supreme Court Weighs Tax Court Jurisdiction in Levy Disputes After Tax Payment: A Deep Dive into Commissioner v. Zuch Navigating ERISA Prohibited Transaction Claims: Insights from Cunningham v. Cornell University…
This week we look at: Navigating the 90-Day Deadline for Employment Tax Redeterminations: The Belagio Fine Jewelry, Inc. Case and Equitable Tolling GWA, LLC v. Commissioner: Substance Over Form and the Nuances of Tax Elections for Disregarded Entities Notice 2025-23: Treasury and IRS Signal Withdrawal of Basis Shifting TOI Regulations and Related Penalties Hobby Loss and Failure to File: A Deep Dive into Himmel v. Commissioner…

1 2025-04-16 A Very Busy Week as the Deadline Approached 1:41:40
1:41:40
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This week we look at: Massachusetts Source Income and the Sale of Stock by a Nonresident Navigating the Valuation Landscape: Insights from Pierce v. Commissioner Personal Liability for Corporate Sales and Use Tax: An Analysis of Matter of the Appeal of B. Wageman Navigating the IRS’s ERC Claim Processing Moratorium and "Risking" Procedures Jurisdictional Prerequisites in Tax Refund Suits: A Case Study of Estate of Robert F. Armitage, Deceased v. The United States Dependency Claims and Child Tax Credits: A Look at Correll v. Commissioner WT Art Partnership LP v. Commissioner: Charitable Contribution Deductions and Valuation Pitfalls Zajac v. Commissioner: Disallowance of Numerous Deductions and Upholding Penalties Hampton v. Commissioner: Public Policy and Disallowance of Shareholder Loss Deduction Revised SIFL Rates for Valuation of Noncommercial Flights: Revenue Ruling 2025-9 IRS Provides Limited Penalty Relief for Certain Micro-Captive Disclosure Statements The Demise of DeFi Broker Reporting: An Analysis of H.J. Res. 25…
This week we look at: Ranch Springs, LLC v. Commissioner : A Case Study in the Valuation of Conservation Easements and the Pitfalls of Aggressive Tax Planning The Duty of Consistency Prevails: A Case Study in Innocent Spouse Relief and Subsequent Asset Claims Navigating the Murky Waters of Investment Tax Credits and Passive Activity Rules: A Deep Dive into Strieby v. Commissioner…

1 2025-03-17 IRS Guidance on When a Scam Generates a Theft Deduction 1:29:51
1:29:51
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This week we look at: Tax Court Finds Taxpayer Failed to Provide a Qualified Appraisal, No Charitable Deduction Allowed Estate Found Liable for $2 Million FBAR Penalty That Applied to the Decedent Taxpayers Filing Court Challenges to Attempt to Obtain Employee Retention Tax Credits Fourth Circuit Overturns Trial Court’s Grant of Summary Judgment to the Government, Finding True Issue of Fact Exists Regarding Whether Statute Remained Open IRS Memorandum Discusses When a Taxpayer Can Claim a Deduction as Victims of Various Scams Under Current Law…

1 2025-03-10 Can We Mostly Ignore BOI Now? 1:13:05
1:13:05
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This week we look at: Treasury and the Corporate Transparency Act (BOI Reporting) Martino v. Commissioner: Alimony Deduction Case Estate of Kalikow v. Commissioner: Estate Tax & Settlement Payments Appeal of A. Markowski: California Source Income for Nonresidents CF Headquarters Corporation v. Commissioner: Taxability of Grants United States v. Gora: IRS Levy Enforcement…

1 2025-03-03 FinCEN Announces BOI Relief and Future Actions 1:15:28
1:15:28
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This week we look at: FinCEN Announcement on BOI Reporting Penalties Tax Court Case: Alan Hamel and Estate of Suzanne Hamel v. Commissioner IRS “Dirty Dozen” Tax Scams for 2025 IRS Adds Tax Documents to Online Accounts Ways and Means Committee Passes Disaster Relief Bills House and Senate Budget Resolutions…
This week we look at: Second Circuit Rules on Section 179D Deductions and Accounting Method Change IRS Guidance on ACA Notice Posting Court Case on CPA Negligence and Trust Return Penalties BOI Reporting Requirement Updates
This week we look at: Deductibility of Losses: Weston v. Commissioner Conservation Easements: Green Valley Investors LLC Automobile Depreciation and Lease Inclusion S Corporation Inadvertent Termination Relief Corporate Transparency Act (CTA) - Government Briefs House Ways & Means Committee Tax Bills…

1 2025-02-10 New Administration Pushes Foward with the CTA 1:14:55
1:14:55
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This week we look at: IRS issues letter ruling on IRA left to trust A taxpayer mistakenly believes the IRS had conceded that his income was not subject to self-employment tax, but it hadn’t The Tax Court denies a taxpayer’s deductions and claimed partnership losses due to incredibly disorganized and inadequate records Taxpayer runs afoul of the “pay first, litigate later” rule when attempting to sue the IRS for a refund in US District Court in response to an assessment A taxpayer’s unprocessed claim for an ERTC refund doesn’t justify CDP relief The BOI - new Administration continues litigation and proposes a new due date, potential filing relief…

1 2025-02-03 A Week of Tax Court Rulings 1:17:04
1:17:04
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This week we look at: Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on Return IRS Finds Most Expenses Related to Taxpayers’ In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213 Taxpayer Denied Innocent Spouse Relief in Tax Court Bench Opinion Tax Court Finds No Issue With the Appeals Office Structure and Staffing Failure to Provide Proof of Filing of Returns Fatal to Taxpayer’s Attempt at Obtaining Relief in CDP Hearing Despite IRS Procedural Errors…

1 2025-01-27 BOI Sees Supreme Court Action But There a Catch 1:13:25
1:13:25
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This week we look at: Funds Taken By Sheriff Were a Valid Loan and Not Income from Embezzlement Tax Court Allows a Reduced Deduction for a Conservation Easement CCA Discusses Issues with Activities of a Private Foundation with Regard to Self-Dealing, Attempted Correction and Jeopardizing Investments IRS Email Discusses Agency’s (Lack of) Obligation to Process Amended Tax Returns Supreme Court Reverses Fifth Circuit Merits Panel, Again Removes Emergency Injunction Against Enforcement of the CTA BOI Reports Despite Supreme Court’s Action on Texas Top Cop Shop, Inc. Ban on Enforcement of BOI Reporting, FinCEN Notes Ban on Enforcement Under the Smith Case is Still in Effect…

1 2025-01-20 SECURE 2.0 Act Proposed Guidance 1:02:42
1:02:42
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This week we look at: IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 property Proposed regulations on catch-up contributions added by the SECURE 2.0 Act Proposed regulations on the automatic enrollment provisions of IRC §414A US Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process case IRS issues final regulations on resolution of tax controversies by the IRS Independent Office of Appeals Under TFA of 2019…

1 2025-01-13 Tax Filing and Payment Relief for California Wildfires and More 1:21:15
1:21:15
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This week we look at: IRS Grants Tax Relief to California Wildfire Victims National Taxpayer Advocate’s Report to Congress and Legislative Recommendations Released Third US District Court Issues BOI Reporting Injunction Tax Court Finds a Building Was Not a Certified Historic Structure as Defined by §170(h) Taxpayer Denied Refund as Court Found the Taxpayer Had Taken the Position That Its Reporting Was an Error Rather Than a Method of Accounting Seventh Circuit Upholds Imposition of Fraud Penalty for an Overstatement of Withholdings Court Finds Taxpayer Submitted Digitally Altered False Documents, Sustained the Fraud Penalty the IRS Proposed IRS Updates Guidance on Section 530 Employment Tax Liability Relief…
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Federal Tax Update Podcast

1 2025-01-06 Digital Assets, BOI, Conservation Easements and Embezzlement 53:56
53:56
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This week we look at: IRS gives relief for specific identification of digital asset basis for certain taxpayers for 2025 only Department of Justice asks the U.S. Supreme Court to Stay the Latest Corporate Transparency Act Injunction IRS no longer to dispute requirement to comply with APA to add listed transactions after the enactment AJCA in 2024 Tax Court rules that merely being in a registered historic area does not make a building a certified historic structure Tax Court finds taxpayer owes tax on over $5.3 million diverted from two retirement plans…
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Federal Tax Update Podcast

1 2024-12-24 IRS Proposes Significant Revisions to Circular 230 54:31
54:31
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This week we look at: Automatic accounting method changes related to §174 extended to years beginning in 2024 BOI report - hectic week, but ultimately no resolution yet for initial report due date 2025 mileage rates published by the IRS IRS finalizes regulations on supervisory approval of penalties IRS proposes revisions to Circular 230…
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Federal Tax Update Podcast

1 2024-12-16 IRS Expands Business Tax Accounts Features and Access 33:16
33:16
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This week we look at: President signs the two tax bills Congress recently passed DOJ asks for stay of injunction issued by US District Court in Texas on enforcement of the CTA IRS expands Business Tax Account access and services that can be accessed via that account
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Federal Tax Update Podcast

1 2024-12-09 Nationwide Injunction on BOI Reporting 57:21
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This week we look at: Congress enacts two tax laws: but neither is the big one that passed the House in January but stalled in the US Senate A Texas US District Court has issued a nationwide temporary injunction barring FinCEN from enforcing the BOI reporting regime DOJ files a notice of Appeal of the Texas Top Cop Shop Inc decision and FinCEN posts information regarding the impact of the case on BOI reports…
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Federal Tax Update Podcast

This week we look at: IRS releases optional form taxpayer can use to make an IRC §83(b) election IRS extends for one year more a transitional 45-day period to perfect research credit claims found to be invalid claims IRS provides additional relief on the issuance of Forms 1099-K
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Federal Tax Update Podcast

1 2024-11-25 IP PINs, Divorced Parents and Children 48:26
48:26
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This week we look at: IRS announces program using IP-PIN to allow taxpayers who find a dependent on their return has already been listed on another to get their return processed immediately The ERC Second Voluntary Disclosure Program ends but the IRS gives some additional relief for withdrawing a claim filed via third-party payer such as a payroll service…
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Federal Tax Update Podcast

1 2024-11-18 End of Partnership Suspense Account at the IRS 58:57
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This week we look at: IRS may stop putting “taxpayer may rely” statements on proposed regulations Tax Court rules partnership basis calculations are cumulative in nature and not stand-alone annual calculations under IRC §705 Latest speculations on what will get through Congress in 2025 - if anything
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Federal Tax Update Podcast

1 2024-11-11 Post Election Issue on Tax Bills and the Reconciliation Process 57:51
57:51
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This week we look at the rules involving the reconciliation process in Congress, the path that it appears most likely any tax bill enacted to deal with the expiration of many TCJA provisions at the end of 2025.
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Federal Tax Update Podcast

1 2024-11-04 Retirement Plan Inflation Numbers 42:56
42:56
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This week we look at: Retirement plan limits announced by the IRS, basically completing the tax inflation adjustments for 2025 IRS emailed Chief Counsel Advice outlines dealing with SECA and the net investment income tax issues arising from a BBA partnership exam
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Federal Tax Update Podcast

1 2024-10-28 IRS Releases Most 2025 Inflation Adjusted Numbers 56:57
56:57
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This week we look at: IRS releases inflation adjusted numbers for most items aside from retirement plans for 2023 IRS has more bad news for those who fail to pay over trust fund taxes to pay other expenses Another US District Court denies a preliminary injunction to bar enforcement of the BOI reporting rules…
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Federal Tax Update Podcast

1 2024-10-21 Staking Returns for One More Try at Court 30:54
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This week we look at: S corporation finds multiple ways to terminate its S status, asks IRS forgiveness which is granted IRS rules condoms are medical expenses for tax purposes IRS adds items to list of preventive care an HDHP can pay without the insured having met the annual deductible PTIN registration opens for 2025 Staking income challenge returns to court…
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Federal Tax Update Podcast

This week we look at: Additional BOI clarifications from online discussions regarding a CPA firm’s reporting obligations and confusions about reporting by entities that don’t register with a state for formation but which do file tax returns
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Federal Tax Update Podcast

This week we look at: DOJ has scheduled a December 2 hearing on the proposed rule to reschedule marijuana BOI reporting confusions that keep coming up as questions in online discussions - time to review
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Federal Tax Update Podcast

1 2024-08-26 IRS ERC Notices of Denial-Comments of the Taxpayer Advocate 1:03:58
1:03:58
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This week we look at: IRS announces the reopening of the ERC Voluntary Disclosure Program on somewhat less generous terms then the first program provided National Taxpayer Adviser discusses issues related to ERC Notices of Disallowance issued by the IRS Copyright 2024, Kaplan, Inc.
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Federal Tax Update Podcast

1 2024-08-05 House Passed Tax Bill Fails to Clear Cloture Vote in the Senate 57:55
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This week we look at: Tax bill fails to clear a procedural vote in the Senate, reducing the likelihood we’ll see the bill enacted before this Congress leaves office US District Court declines to issue preliminary injunction requiring the IRS to terminate the ERC claim moratorium, but finds much the court liked in the plaintiff’s arguments.…
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