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Bankruptcy, Insolvency & Debt Discharge

Charitable Contributions

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Deductions and Credits

Estate & Gift

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Nontaxable Exchanges

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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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Category: Deductions and Credits

Abandonment Loss; IRS Denial of Abandonment Loss Treatment; IRC: 165.

Abandonment Loss; Removal of Leasehold Improvements as Abandonment; IRC: 165(a), 280B.

Adoption; Dependent Eligibility; Adoption Expenses; IRC: 213(a), 152(a) and 152(b)(2), 23.

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

Amortization; Amortization of Intangible Assets, Contingent Purchase Price; IRC 195.

Amortization of Goodwill; Amortization of Goodwill Resulting from Section 743(b) Step-Up; IRC: 743(b), 197, 754, 755.

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

Bad Debt; Bad Debts: Renewed Notes; IRC: 166.

Bad Debt; Business Bad Debt: Loan to Employer Corporation; IRC: 166(d)(2) .

Bargain Sale to Charity; Issues Related to Bargain Sale to Charity of Principal Residence; IRC: 170, 1001, 1011.

Cancellation of Debt; Forgiveness of Accrued but Unpaid Interest by a Cash Basis Taxpayer; IRC: 108(e)(2).

Capital Contributions; Guaranty Matter; IRC: 166(b).

Carryover of Charitable Contributions; Designating Carryovers to be Used: AMT vs. Non-AMT; IRC: 170.

Charitable Contributions; Charitable Contributions of Appreciated Property as Sale or Exchange; IRC: 1001, 170.

Child Care Credit; Claiming the Difference Between Actual Expenditures and Amount from Cafeteria Plan; IRC: 21(c), 125, 129.

Contribution of Appreciated Property; Contribution of Property Subject to a Prearranged Sale; IRC: 1011(b), 1001.

Contributions; Contribution of Self-Produced Software; IRC Section 170.

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

Depreciation: ADS Elections; Effect On Regular Tax/AMT; IRC 56.

Depreciation; Depreciation of Electrical Generation Equipment; IRC: 168(e).

Depreciation; Depreciation of Golf Course Components; IRC 167.

Depreciation; Depreciation of Material Handling Racks; IRC: 168.

Depreciation; Depreciation of Parking Structure; IRC 168.

Depreciation; Mandatory Depreciation; IRC: 1001, 1011, 1012, 1016, 168(g).

Depreciation; Placed in Service Issues, Staged Completion of Building; IRC: .

Deprecation of Inherited Property; Treatment of Step-up Basis; IRC: 1014, 168.

Disability Insurance Plan; Excludability from Employee's Income and Deductibility by Corporation; IRC: 106, 162(a).

Disability Insurance Plan; Tax Effects of Plan for Shareholders/Employees; IRC: 106.

Dividends Received Deduction; Dividends Attributable to a Foreign Sales Corporation; IRC: 245, 246(b), 172(d)(5).

Double Deductions; Charitable Deduction for Waste and By-Products; IRC: 1011 and 1012; 170 and 162.

Educational Expense; Computer-Related Educational Expenses; IRC: 280F(d)(3), 212, 162.

Employee Leasing; Employee Leasing to Achieve C Corporation Employee Benefits for Non-C Corporation Employers; IRC: 414(n), 401(a), 408(k).

Fines and Penalties; Non-Deductible vs. Potentially Deductible Components; IRC: 162(f).

Income in Respect of a Decedent; Issues Relating to Deductions from Estate Tax Attributable to IRD; IRC: 691(c).

Individual Retirement Account; IRA Investment Advisory Fees, Deductibility of; IRC: 212.

Installment Sales; Self-Canceling Installment Notes (SCIN's); IRC: 691(a)(2), 691(a)(5), 453B(f).

Interest Expense; Debt Used to Pay Estate Taxes; IRC Sections: 163(h).

Interest Expense; Gifted Mortgage Interest; IRC: 163.

Interest Expense; Interest on Debt to Carry S Corporation Stock; IRC: 1366(d)(1), 1367.

Interest Expense; Interest on Insurance Loans; IRC: 264, 163(d), 469(e).

Interest Expense; Interest on Insurance Policy Loans; IRC: 264.

Interest Expense; Investment Interest Carryforward; IRC: 163.

Interest Expense; Investment Interest Carryover; IRC 163.

Interest Paid to Foreign Lender/Gifts by Nonresidents; Various Issues; IRC: 102, 267(a)(3), 1442, 1441, 2501(a)(2).

Jobs Tax Credits Carryover; Unused Job Tax Credits, Survival of Section 196 Carryover on Termination of S Election; IRC: 196, 1371(b).

Lease Down Payments; Amortization of "Buy-Down" of Lease; IRC: 167.

Leasehold Improvements and Paving Costs; Acceptable Cost Recovery Periods; IRC: 168.

Loss Deduction; FCC Licenses; IRC: 165.

Losses; 1244 Stock Loss, Manner of Disposition; IRC: 1244.

Losses; Abandonment Losses; IRC: 165(a).

Losses; Abandonment of Intangible Assets; IRC 165.

Losses; Casualty Loss: Damage to Value from Buyer Reluctance; IRC: 165.

Losses; Casualty Loss: Election to Deduct Loss in Preceding Year, Availability for Trusts; IRC: 165(i).

Losses; Casualty Loss: Payment of Tort Judgment; IRC: 165(c)(3).

Losses; Depositor Losses from Failed Bank; IRC: 165(l).

Losses; Gambling Losses, Markers as Substantiation; IRC: 165.

Losses; Theft Loss/Bank Seizure; IRC: 165(g).

Meals and Entertainment Expenses; Meals and Entertainment Expenses, Independent Contractors; IRC: 274, 62(c).

Medical Deduction; Medical Deduction for Convalescent Home, Alzheimer's Patient; IRC: 213(d)(1)(C), 7702B(c).

Medical Savings Account (MSA); MSA for Partners and S Corporation Shareholders; IRC: 105, 106, 1372(a), 707(c).

Multi-Tier Partnerships; Section 754 Election/Timing of Theft Loss from Embezzlement; IRC: 165(e), 754, 743(b).

Net Operating Loss Carryovers; Proper Treatment of NOL Carryovers; IRC: 172(b).

Net Operating Losses; Use of NOL's Against Built-In Gains Tax; IRC: 1374(d)(2)(A)(ii), 1375(b)(1)(B), 172.

Partnership Expenses; Expenses Incurred by General Partner; IRC: 162, 212.

Payment to Protect Business Reputation; Discussion of Deductibility of Payments; IRC: 162.

R&D Credit; Special Rule for Computing "Base Amount"; IRC: 41.

Real Property Taxes; Real Property Taxes Assessed Against Local Benefits; IRC: 164(c)(1).

Reduction for Meals and Entertainment Expenses; Applicability of 50% Reduction to Expenses Related Directly to Business Operation; IRC: 274(n), 274(e).

Rehabilitation Credit; Issues Related to Certified Historic Structure; IRC: 49(a)(1).

Reimbursed Meal Expenses; Accounting of Expenses by Service Provider; IRC: 274(n).

Rental Use of Dwelling Unit; Disposition Proceeds as Gross Income/Allocation Between Business and Personal Usage if Business Usage Has Varied Over the Life of the Asset; IRC: 280A(c)(5).

S Corporation; Automobile Reimbursements; IRC: 163(h)(2)(A).

S Corporation; Research Credit; IRC: 41(g), 53.

Section 108(e)(2); Various Issues; IRC: 108(e)(2), 163(d)(5)(A), 469(e)(1).

Section 170(e)(5)(B); Discussion of the Meaning of Section 170(e)(5)(B); IRC: 170.

Section 179; Assets Placed in Service and Disposed of in Same Year; IRC: 179(b)(2).

Section 179; Purchase of Assets from Related Parties; IRC: 179.

Section 179; Section 179 Election on Amended Return; IRC: 179.

Section 382 ; Application of Section 382, Rescission of Stock Sale; IRC: 382.

Self-Employment Tax; Effect of NOL Carryback; IRC: 1401 through 1403, 172.

SEP; Timing of Deductions when SEP Year Differs from Employer's; IRC: 404(h)(1)(A).

Standard Mileage Allowance; Present State of the Law; IRC: 162.

Stock Redemptions; Various Issues; IRC: 302, 318, 311, 166, 368.

Theft Loss; Insurance Claim; IRC 165(h)(4)(E).

Transfer of Residence to Living Trust; Home Mortgage Interest/Deferral of Gain on Sale of principal Residence/Trust Filing Issues; IRC: 1034 , 671 through 677, 163(h).

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

Unreimbursed Expenses; Unreimbursed Expenses--Shareholder/Employee of S Corporation; IRC: 62.