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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 January 28, 2011

    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 January 28, 2011

    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 July 13, 2012

    Diversifying Concentrated Positions in the Most Tax-Efficient Manner

    Article This item explores techniques that may be used to the advantage of investors wishing to diversify concentrated securities positions in a tax-efficient manner
    Published on January 13, 2012

    Software and California Sales and Use Tax

    Article This item addresses the sales and use tax implications of canned software (prewritten programs) under two recent California cases in light of that state's current statutory scheme
    Published on April 20, 2012

    Dismissal of Tax-Driven Bankruptcy Plan Affirmed

    Article The Seventh Circuit affirmed a bankruptcy court’s refusal to confirm a bankruptcy plan and its dismissal of the bankruptcy proceeding because the principal purpose was to avoid taxes. The court said the filing was in bad faith and did not serve the proper purpose of bankruptcy law
    Published on August 01, 2010

    Tax Court in the Classroom

    Article This column describes mock Tax Court: An exercise that has assisted students in improving their communication and analytical skills and has proven instrumental in helping them prepare for their professional careers in accounting
    Published on January 13, 2012

    IRS Taking Firm Approach to Ozone-Depleting Chemical Excise Tax Compliance

    Article The IRS has recently reinvigorated its examination of the ozone-depleting chemicals tax, adopted a strict interpretation of the regulations, and instituted a laboratory testing program to detect ODCs in printed circuit boards
    Published on January 28, 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 02, 2010

    Employment Tax Consequences of a Corporate Change of Control Event

    Article This item examines the employment tax consequences related to a corporate change of control event. Those consequences generally depend on the type of event, namely whether there is an asset purchase, a merger, or a...
    Published on October 04, 2011

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