Individuals

Corporations

Estates & trusts

Partnerships & LLC's

Accounting Periods & Methods

Bankruptcy, Insolvency & Debt Discharge

Charitable Contributions

Compensation & Employee Benefits

Deductions and Credits

Estate & Gift

International

Miscellaneous

Nontaxable Exchanges

Real Estate

Sales and Exchanges

Tax Returns, Examinations & IRS Procedure

This library contains hundreds of high-quality technical tax memoranda on a wide variety of topics. The memoranda are organized by topics and are fully word-searchable. This library is a rich resource of already-solved tax problems. Use it as a starting point for your own research.

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The Tax Resource Group Memo Library

Category: Accounting Periods and Methods

Accounting for Sale of Stock; Specific Identification of Shares Sold; IRC: 1012.

Accrued Commission Income; Employee Buyout of Employer's Assets Including Accrued Commissions Payable to Employee; IRC: 61.

Adoption of Fiscal Year; Filing an Invalid Tax Return: Affect on Tax Year; IRC: 441.

Advertising Costs; Capitalization vs. Expense of Costs; IRC: .

Alternative Minimum Tax; Effect of Difference in Accounting Methods; IRC: 56(g)(4)(B).

Amortization of Intangibles; Covenant-Not-To-Compete, Use of "Likeness" of Individual; IRC: 197.

Capitalization of Interest; Real Property Held for Development: Applicability of Section 266; IRC: 266, 263A.

Carrying Costs, Election to Capitalize; Capitalization of Carrying Costs of Nonbusiness Property; IRC: 266.

Carrying Costs, Unproductive Property; Capitalization vs. Deduction of Expenses; IRC 266.

Cash Method of Accounting; California LLC; IRC: 448(a)(3), 448(d)(3), 461(i)(3).

Cash Method of Accounting; Checks Written Against Insufficient Funds; IRC: 267(a)(2), 461(h), 404.

Cash Method of Accounting; Contractors; IRC: 446.

Cash Method of Accounting; Maker of Orthotic Devices; IRC: 446.

Cash Method of Accounting; New Taxpayer Letter; IRC: 446.

Cash Method of Accounting; Taxicab Company; IRC: 446.

Change of Accounting Method; Cash Basis to Completed Contract--Approval Procedure; IRC: 446, 460.

Change of Accounting Method Required by State; Procedures for Missed Deadline; IRC: 460, 446, 9100.

Change of Taxable Year; Taxpayer with an NOL but Subject to AMT: Effect on Automatic Permission to Change; IRC: 442.

Completed Contract Method of Accounting; Real Estate Construction Defined; IRC: 460.

Corporate Merger/Accounting Methods; Survival of method of accounting after merger; IRC 381.

Corporate Reorganization; Deduction of Target's Accrued Expenses (Part A); Sections: 461(h).

Corporate Reorganization; Deduction of Target's Accrued Expenses (Part B); Sections: 461(h).

Cost Accounting; Inventory Treatment of Freight and Transportation Costs; IRC: 471.

Deductions for Compensation and Employment Taxes; Effects of Failure to Remit Employment Taxes on Employer's Deductions; IRC: 162, 461.

Discount on Tax-Exempt Bonds; Accounting for OID and Market Discount; IRC: 1288(a)(2), 1276, 1278.

Examinations; Statute of Limitations for Individual Examinations; IRC: 6501(e), 453.

Fixture--Definition of; Storage Tanks as Real Property; IRC: 460.

Income, Exclusion of Contract Prepayments; Executory Sales Agreement or Contract for Development?; IRC: 460.

Income Recognition; Income from Unredeemed Trading Stamp Liability; IRC: 451.

Installment Liquidation; S Corporation Installment Liquidation--Time Period Limitations; IRC: 453(h), 453(B)(h), 331.

Installment Sales; Allocation of Installment Proceeds Among Classes of Assets Sold; IRC: 453.

Installment Sales; Installment Sales--Purchase Price Adjustments; IRC: 453B(a), 1231.

Installment Sales; Installment Sale Reporting; IRC: 453.

Interest Income; Cost Recovery Method; IRC: 61.

Publisher's Election to Defer Prepaid Subscription Revenue under Section 455; Effects of Failure to Make Affirmative Election; IRC: 455.

Purchase Price Allocations; Change in Purchase Price Allocations as Change in Accounting Method; IRC: .

Sale of Dealer Notes; Sale of Dealer Notes Between Related Parties; IRC: 1221(4), 267(a)(1) and 707(b).

Sale of Oil & Gas Property; Treatment of Oil and Gas Interest For Purposes of Sections 453(g) and 1239; IRC: 1239, 453(g).

Sale of Property to Related Party; Effects on Installment Reporting Provisions; IRC: 453, 1060, 197.

Section 481(a) Adjustment; Effect of Conversion to S Corporation; IRC: 481(a)

Section 481(a) Adjustment--Recapture; Transfer of 481(a) Adjustment to Successor Entity; IRC: Section 481(a).

Signing Bonus; Immediate Deductibility vs. Capitalization; IRC: 162, 263.

Timing of Income Recognition; Lease with Option to Purchase; IRC: 1001, 1234.

Uniform Cost Capitalization; Computer Software Development Costs; IRC: 263; 174.

Uniform Cost Capitalization; UNICAP on Property Held for Investment; IRC 263A.