by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
Provision for a “Minimum Gain Chargeback” exists in nearly every partnership agreement and limited liability company operating agreement. Few people, however, actually understand the need for such provision or its function, and few attorneys – even...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
Under normal assessment procedures, the Internal Revenue Service is prohibited from assessing and collecting a tax deficiency from a taxpayer until the taxpayer has been sent a valid, statutory notice of deficiency and has been given a 90-day (or, if applicable, a...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
The Korn Law Firm, P.L. / Tel (239) 354-4300 If you are expecting a loss for the tax year from your interest in a partnership, but do not currently have enough basis in your partnership interest to allow a full deduction, several solutions exist. In general, a partner...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
On January 26, 2010, the Internal Revenue Service announced that it will be requiring certain filers to provide detailed information about their “uncertain tax positions” that affect their income tax liability. Initially, this disclosure will be required...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
A common question from our clients – corporate, partnership and individual alike — is “how far back can we go” in order to amend a return or obtain a refund. This simple question belies a common, and understandable, misunderstanding. Although...