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    Defending R&D Credits

    Article This article highlights and analyzes some recent decisions concerning the research and development (R&D) tax credit and IRS administrative practices when auditing R&D credit claims, most notably the Union Carbide decision in the Tax Court
    Published on May 01, 2010

    Analyzing the Tax Implications of Grants Received for Investment Tax CreditEligible Property

    Article The recent availability of grants in lieu of the production tax credit (Sec. 45) and the investment tax credit (Sec. 48) has become a well-documented source of funding for the installation of certain energy property
    Published on August 01, 2010

    Tax Court Again Holds That Innocent Spouse Relief Limit Is Invalid

    Article Despite being overruled by the Seventh Circuit in an earlier case, the Tax Court has again held that the regulatory two-year limitation period for filing a claim for equitable innocent spouse relief under Sec. 6015(f) is invalid. This item assesses...
    Published on November 01, 2010

    The Qualified Therapeutic Discovery Project Tax Credit and Grant

    Article Included in the 2010 Patient Protection and Affordable Care Act are a few new income tax credits. In particular, there is one that many new startups and growing health care industry enterprises may benefit from—the qualifying therapeutic discovery project credit (Sec. 48D
    Published on August 01, 2010

    Reporting Uncertain Tax Positions

    Article This item explores the differences between financial statement reporting and federal income tax return disclosure in preparing for disclosure of uncertain tax positions on the Schedule UTP
    Published on April 01, 2011

    Revised LMSB Examiner Procedures for Tax Preparer Penalty Cases

    Article This item discusses the continuing trend of shifting accountability for tax return compliance to return preparers by raising preparer conduct standards, broadening the definition of tax return preparers, and increasing preparer penalties for violations
    Published on November 01, 2010

    Tax Return Preparers Win Partial Victory in Fraudulent Credit Scheme Case

    Article A district court found that two tax return preparers who had participated in a fraudulent scheme involving credits for fuel from nonconventional sources did not know the scheme was fraudulent and dismissed the IRS’s requests...
    Published on December 01, 2011

    Final Form and More Guidance on Small Business Health Care Tax Credit

    Article The IRS released a new form and guidance relating to the small business health care tax credit for the 2010 tax year. The guidance discusses issues relating to employers’ eligibility for the credit and other eligibility issues
    Published on February 01, 2011

    Death and Taxes Executors Beware

    Article The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act revised tax law for estates of decedents dying in 2010, 2011, or 2012. The new rules apply for 2010 unless an...
    Published on April 01, 2011

    Reorganizations and Tax Attribute Survival

    Article Whether tax attributes will survive corporate tax reorganizations often becomes a critical consideration in assessing the ramifications of a proposed transaction. This item discusses issues surrounding these reorganizations and emphasizes the...
    Published on December 01, 2010

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