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...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
The Korn Law Firm, P.L. / Tel (239) 354-4300 An interest in a partnership is considered a capital asset. Loss upon sale of a partnership interest is therefore generally treated as a capital loss. But can the sale of a partnership interest be restructured to permit...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
Under the Internal Revenue Code and specifically under Treasury Regulations Section 301.6331-1, the Internal Revenue Service has broad authority to make continuing levies and successive seizures on recurring and periodic forms of compensation. A levy on salary or...
by Tyler B. Korn, Esq. | Jul 29, 2010 | Articles
Seeking an end-run against its recent losses in court, the Internal Revenue Service has issued temporary Treasury Regulation, Section 301.6229(c)(2)-1T. Under the new temporary Treasury Regulation, an understated amount of gross income that results from an...
