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2/10 net 30
2 and 20 (2/20)
5 by 5 power
Adjusted Basis of Partnership Property a/k/a IRC §754 election
Ashley Albright, no non-debtor members in a SMLLC
All-Events Test
Allowed or Allowable
Amended Return
Appropriate and Helpful
Arrowsmith Doctrine (expenses paid after dissolving a business entity) CC 200518014 / PLR-129030-04
Assessment Statute Expiration Date (ASED)
Assignment of Income (old webpage link)
At-Risk Rules
Audit Reconsideration
Audit Technique Guide
Badges of Fraud
Bank Routing Transit Number (RTN)
Bank Depositor Account Number (DAN)
Bifurcation
Blockchain
Business Purpose Doctrine
C2C see “loan-out company” below
Can-of-Worms
Carried Interest a/k/a IRC §83(b) election
Centralized Authorization File (CAF)
Chief Counsel Advice (CCA)
Claim of Right (§1341)
Clawback (§1341 election)
Code and Regs.
Collection Due Process (CDP)
Collection Statute Expiration Date (CSED)
Community Property
Constructive Ownership and Rules of Attribution (§318 §1-318-1 §267)
Credit Elect
Criminal Investigation Division (CID)
Cross Species Conversions and Mergers
CT Policy Statements
Currently Not Collectible (CNC)
Corporation Tax:
State and Local Tax (SALT)
Joyce rule
Finnigan rule
Nowhere Income
Single Sales Factor
Throwback rule
Throwout rule
Geoffrey Loophole
Decedents:
IRS Form 56 (Notice Concerning Fiduciary)
IRS Form 8855 (§1.645-1(c) Election)
IRS Form 8971 (Notification of basis of assets to beneficiaries)
TAM 199933001 (retroactively changing of basis of assets to beneficiaries)
Signing final Form 1040
Switching final Form 1040 from MFJ to MFS
Allocate Estimated Taxes from the Final Form 1040
Report U.S. Savings Bonds on final Form 1040 (§454(a) election) Rev Rul 68-145
Income with respect of a decedent (IRD)
Claim an Estate Tax Deduction for IRD (Regs. §1.691(c)-2(a)(1))
Claim deductions in respect of a decedent on Estate Tax Returns (DRD)
Manage Distributions to Minimize Overall Tax
Select a Fiscal Year End for the Estate
Prepare a “First and Final” Return When Possible (One Return concept – a return IRC §6011(a))
Prepare Form 1041 on the Accrual Basis
Set Aside Income from Charitable Assets
Debt-Financed Acquisition
Declaration of Representative
Deficit Restoration Requirement
de minimis
Demutualization
Dependent Care Assistance Program (DCAP)
Deposit vs. Payment
Disguised Sales
Doctrine of Election
Duty of Consistency
Earned Income Tax Credit (EITC)
Economic Performance
Economic Substance
Elect Out of Subchapter K Partnership Rules
Electing Investment Partnership (EIP)
Electronic Federal Tax Payment System (EFTPS)
Electronic Filing Identification Number (EFIN)
Electronic Return Originator (ERO)
Electronic Transmitter Identification Number (ETIN)
Employee Advances vs. Employee Loans
Employee Benefit Plan
Employees’ $5,000 death benefit (§1.101-2)
Employer Identification Number (EIN)
Entity Classification Election
Equitable Recoupment IRC §6214(b)
Exemption Certificate Number (ECN)
Evidence:
Benefit of Assumption
Beyond Reasonable Doubt (Criminal proceedings)
Clear and Convincing (Civil & Criminal proceedings)
More likely than not (Civil proceedings)
Preponderance of Evidence (Civil proceedings)
Presumption of Innocence (Criminal proceedings)
Alford Doctrine
No contest (nolo contendere)
Fair Market Value (FMV)
Field Service Advice (FSA)
Financial Crimes Enforcement Network (FinCEN)
Financial Disability
First-Time Abate (FTA)
Foreign Bank Account Report (FBAR)
Foreign Bank and Financial Accounts, Report of (FinCEN Report 114) due if $10K foreign assets any time during the year.
Form 8938 (instructions) due if filing married-joint and $100K foreign assets on Dec 31st or $150K anytime during year (if not married-joint, then half these amounts).
Foreign Tax Credit
Foreign Tax Paid deduction
Gallenstein Decision of 1992 (pre-1977 assets of married couple IRC §2040)
Garn-St. Germain Depository Institutions Act of 1982 12 U.S. Code § 1701j–3
Kwok v. Transnation Title Insurance Company (2009) 170 CA4th 1562
General Counsel Memorandums (GCM)
Generic Legal Advice Memorandums (GLAM)
Groetzinger Decision of 1987 (trade or business IRC §183)
Guaranteed Payments to Partners (GPP)
Hardcore Payment Tracers (HCPT)
Hardcore Payment Tracer Functions (HPTF)
Head of Household
Hobby Loss Rules
Homeowner Association, Form 1120-H election
Homeowner Association, Rev. Rul. 70-604 election
Honest and Reasonable
Hot Assets under IRC §751
Hot Stock under IRC §355
Hot Interest rule under IRC §6621(c)
Identity Theft
Identity Protection Specialized Unit
Income in Respect of Decedent §691 (IRD)
Internal Revenue Bulletin (IRB)
Internal Revenue Code (IRC)
Internal Revenue Manual (IRM)
Internal Revenue Service (IRS)
IRS Notices and Announcements
IRS Revenue Rulings and Revenue Procedures
Itemized Elected (IE)
Lease vs. Buy
Liquidation-Reincorporation Doctrine
Loan-Out Company IRS Audit Technique Guide California 2019 Labor Code section 2750.3
Look-Through Rule
Mark-to-Market (M2M or MTM)
Mark-to-Market (Retroactive)
Material Participation
Mazel Tov Bonds
Medicare Contacts
Meals & Entertainment
National Nexus Program
Net Investment Income Tax (NIIT or Obamacare tax)
Net Operating Loss (NOL)
Nominee / T.C. Memo. 2015-174
Non-Collection Due Process
Non-Passive Activity
Non-Willful (OVDP Streamlined)
Offer in Compromise (OIC)
Office in the Home
Offshore Voluntary Disclosure Program (OVDP)
Ordinary and Necessary
Origin of the Claim
Passive Activity Loss
Passive Activity Rules
Passive Income Generator (PIG)
Payment-in-Kind (PIC)
Personal Goodwill – Norwalk vs. Commissioner (TCM 1998-279)
Personal Goodwill – Martin Ice Cream Co., 110 T.C. 189 (1998)
Personal Goodwill – Bross Trucking, TC Memo 2014-107 (2014)
Ponzi Scheme Losses
Power of Attorney (POA)
Practitioner Priority Specialty line
Preparer Taxpayer Identification Number (PTIN)
Private Letter Ruling (PLR)
Protective Claim for Refund (within the SOL time period)
Public Law 86-272
Publicly Traded Partnership (PTP)
Qualified Amended Returns (QAR) Treas. Regs. §1.6664-2(c)(2)
Qualified Income Offset Provision
Qualified Joint Venture (QJV)
Qui Tam, False Claims Act – Whistleblower awards and legal fees – Comm’r v. Banks
Real Estate Professional
Realization Method
Reasonable Cause
Receipt and Control
Recurring-Item Exception
Refund Statute Expiration Date (RSED)
Related Party
Return Preparer Office (RPO) letter 5571
Return Preparer Office (RPO) letter 5572
Return Preparer Office (RPO) letter 5573
Return Preparer Office (RPO) letter 5574
Rev. Proc. 99-17
Rev. Proc. 2015-14
Revocation of M2M
Rollovers as Business Start-Ups (ROBS)
Royalties, patents (long-term capital gain) IRC §1235
Royalties (capital gain) Rev. Rul. 60-226
Royalties (Schedule C and S/E tax)
Royalties (Schedule E and no S/E tax)
Section 179 election to expense capital costs, rather than depreciate them
Section 1.266-1 election to capitalize costs to carry property, rather than expense them
Section 529 educational savings plan
Secure Object Repository (SOR)
Self-Charged Interest
Self Rental
Settlements, Compensatory & Punitive – Publication 4345
Social Security Number (SSN)
Spiffs & Incentive Payments
Statute of Limitation
Step Transaction
Substance Over Form
Substantial Compliance Doctrine
Substantial Economic Effect (SEE)
Substantial Variance Doctrine (Article by Megan L Brackney)
Substitute For Return (SFR)
Service Filed Return (SFR)
Superseding Return
Sutter Rule
Syndication Cost Regs. §1.704-1(b)(2)(iv)(i)(2)
Austin Submission Processing Campus (AUSPC)
Austin Submission Processing Center
Cincinnati Submission Processing Campus (CSPC)
Cincinnati Submission Processing Center
Fresno Submission Processing Center
Kansas City Submission Processing Center
Ogden Submission Processing Center
Tangible Property Regulations (TPR)
Tax Benefit Rule
Tax Information Authorization (TIA)
Tax Directive No. 128
Tax Matters Partner (TMP)
Tax Seizure Auction
Taxpayer Identification Number (TIN)
Tax Equity and Fiscal Responsibility Act (TEFRA)
Technical Advice Memorandum (TAM)
Three Prong Test (all-events test)
Three Prong Test (independent contractor)
Three Prong Test (UBTI)
Timely mailing treated as timely filing and paying (IRC §7502)
. Certified mail required (Regs. §301.7502-1(c)(2))
. When the due date falls on Saturday, Sunday or Holiday (Regs. §301.7503-1)
. Definition of “a month” (Regs. §301.6651-1(b))
Trade or Business
Trader Status
Transcript Delivery System (TDS)
Transmitter Control Code (TCC)
Travel & Entertainment (T&E)
Trusts:
Charitable Lead Trust
Charitable Remainder Annuity Trust (CRAT)
Charitable Remainder Unitrust (CRUT)
Complex Trust
Grantor Trust
Intentionally Defective Grantor Trust (IDGT)
Pure Trust Organization (PTO)
Qualified Disability Trust
Qualified Funeral Trust
Qualified Personal Residence Trust (QPRT)
Simple Trust
Special Needs Trust (SNT)
Uniform Capitalization rules (UNICAP)
Viatical Settlements (less than 24 months to live)
Life Settlements (longer life expectancy)
Voluntary Disclosure Practice (VDP)
Voluntary Disclosure Program (VDP)
Wash Sale Rule
Whiteco test