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.

The Tax Resource Group Memo Library Category: Individual Taxation Adoption; Dependent Eligibility; Adoption Expenses; IRC: 213(a), 152(a) and 152(b)(2), 23. Assignment of Income--Divorcing Spouses; Income From Rental Property Treated As Community Property; IRC 1041. Bad Debt; Business Bad Debt: Loan to Employer Corporation; IRC: 166(d)(2) . Bankruptcy Transactions; Various Issues; IRC: 108, 1398, 465. Basis; Basis of Inherited Property, Remainder Interest; IRC 1014. Business Use of Residence; Depreciation of Motor Home; IRC 280A. Capital Gains Tax Rate; Election to Have Capital Gains Taxed at Ordinary Income Rates; IRC: 1(h). Casualty Loss; Casualty Loss, Timing, Subsequent Discovery of Additional Damage; IRC 165. Child Care Credit; Claiming the Difference Between Actual Expenditures and Amount from Cafeteria Plan; IRC: 21(c), 125, 129. Community Property; Separated Spouses, Allocation of Income; IRC: 66(a). Disability Insurance Plan; Excludability from Employee's Income and Deductibility by Corporation; IRC: 106, 162(a). Estimated Taxes; Estimated Taxes, Prior Years Liability; IRC 6654. Estimated Taxes; Required Estimated Tax Payments; IRC: 6654(d). Extension of Time to File Returns; Extensions for Divorcing Taxpayers; IRC: 6081. FICA Tax; FICA Liability for Disability Payments; IRC: 3121(a)(4). Gratuitous Forgiveness of Mortgage Loan; Inclusion of Accrued Interest in Taxable Gift/Inclusion of Accrued Interest in Income; IRC: 61, 2501. Health Insurance for Self-Employed Persons; Effect of Hiring Proprietor's Spouse; IRC: 105, 162. Incentive Stock Options; General Issues; IRC: 422(b)(1), 83. Income; Taxation of Annuity Payments; IRC: 72(b); 402(d)(4)(A). Income; Taxation of Escheated Funds; IRC: 61. Income; Taxation of Social Security Disability Benefits; IRC: 86. Income, Worldwide Taxation; U.S. Green Card, Citizen of Chile, Sale of Non-U.S. Real Property; IRC: 61. Individual Retirement Account; Domestic Requirement; IRC: 408(a); 7701(a)(9); 72(t). Individual Retirement Account; IRA Investment Advisory Fees, Deductibility of; IRC: 212. Individual Retirement Account; Minimum Distribution Requirements, Post Mortem; IRC: 408, 401. Individual Retirement Account Withdrawal; Applicability of Section 72(t) to Distributions from IRA Rolled Over from Qualified Plan on Death of Participant; IRC: 72(t). 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). Jointly Owned Property; Electing Out of Partnership Provisions; IRC: 731, 732, 168(i)(7). Lawsuit Settlement; Ordinary vs. Capital Gains Tax Issues; IRC: 1222, 83(b). Lawsuit Settlement; Taxability of Personal Injury Awards; IRC: 104(a)(2), 1605. Lawsuit Settlement; Tax Treatment of Broker Mismanagement Settlement; IRC: 61. Lawsuit Settlement or Judgment; Taxation of Malpractice Judgment; IRC: 104(a)(2). Losses; 1244 Stock Loss, Manner of Disposition; IRC: 1244. Losses; Abandonment Losses; IRC: 165(a). Losses; Bad Debt; IRC: 166, 453B(f). Losses; Gambling Losses, Markers as Substantiation; IRC: 165. Losses, Section 1244 Stock; Contribution to Insolvent Corporation; IRC: 1244. Losses; Suspended S Corporation Losses, Availability after Sale of Stock; IRC: 1366(d). Losses; Theft Loss/Bank Seizure; IRC: 165(g). Part-Gift, Part-Sale of Home; Various Issues; IRC: 1034, 121, 2501. Passive Activity, Disposition of; Assignment as Complete Disposition; IRC: 469(g), 172. Patents; Sale of Patent Application; IRC 1254. Principal Residence, Sale of; Cost of Replacement Residence; IRC: 1034. Qualified Domestic Relations Order (QDRO); Section 72(t) Penalty on QDRO Distributions; IRC: 72(t). Qualified Retirement Plans; 10-Year Averaging; IRC: 401. Real Estate Dealer Status; Taxpayer Stroke as Evidence of Change of Intent to Hold Property for Sale to Customers; IRC: 1221. Redemption of Stock; Redemption of Stock in Connection with Divorcing Spouses; IRC: 1041, 302(b)(3). Rental House, Sale of; Exclusion of Gain; IRC: 121, 1034. 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). Residence--Replacement of; Section 1034: Effect of Renting Part of Principal Residence; IRC: 1034(a). Residence, Sale of; Availability of Section 1034--Husband and Wife Living in Separate Residences; IRC: 1034. Residence, Sale of ; Divorced Couple--Issues Related to Gain on Sale; IRC: 1034, 121. Residence, Sale of ; Interaction of Section 121 and Installment Sale, Post Mortem Collections; IRC: 121, 453B(c), 691(a), 453(d). Residence, Sale of; Multiple Replacement Properties; IRC: 1034(c)(4). Residence, Sale of; Section 121 Exclusion, Partial Business Use; IRC: 121, 1034, 280A(c)(6). Residence, Sale of; Section 1034 Replacement of Personal Residence, Effect of Marital Status; IRC: 1034, 6013. Restoration of S Corporation Debt Basis; Exception to General Basis-Timing Rule; IRC: 1367(b)(2)(B). Retirement Distributions; Early Withdrawal from a Qualified Pension Plan; IRC: 402(d), 72(t), 404(k). Scholarships; Exclusion of Scholarship Paid at Completion of Education; IRC 117. Self-Employment Tax; Effect of NOL Carryback; IRC: 1401 through 1403, 172. Self-Employment Tax; Commodities Traders and Dealers, Traders, Investors in Securities; IRC: 1401 through 1403, 1256. Self-Employment Tax; Income From the Rental of Self-Service Warehouses; IRC: 1402, 707(c), 706(a). Self-Employment Tax; Limited Liability Companies, SE Tax, and Real Estate Rentals; IRC 1402. Self-Employment Tax; Recharacterization of Rental Income Under Section 469, Effect on SE Tax; IRC: 1402(a)(1), 469. Self-Employment Tax; SE Taxability of Guaranteed Payment to Widow of Retired Partner; IRC: 1402. Self-Employment Tax; SEP; Director Fees; IRC: 1402, 408(k)(7)(B). Self-Employment Tax; SEP; Insurance Commissions; IRC: 1402, 408(k)(7)(B). SEP; SEPs for Older Taxpayers; IRC: 408(k), 219. SEP; SEP Contributions: Eligible Earnings; IRC: 414(c), 408. SEP; SEP for Statutory Employee; IRC: 3121(d)(3), 415(c). SEP/IRA; Deductibility of Contributions; IRC: 162. Social Security Benefits from Foreign Nations; U.S. Tax Treatment of Social Security Benefits Paid by Norway and Germany; IRC: 86. Statute of Limitations; NOL Carryback Claim, Time Limitation for Filing; IRC: 6511(d)(2)(A). Stock Sales; Specific Identification of Shares Sold; IRC 1012. Tax Benefit Rule/AMT; Tax Benefit Rule Gain Adjustment for Prior AMT Items; IRC: 58(h), 59(g). Tax Home, Multiple Business Locations, Commuting Expense; Use of Aircraft for Commuting/Transportation; IRC 162. Temporary Rental of Residence; Passive Activity Loss Provisions vs. Rental Use of Residence Rules; IRC: 469, 280A. Transfer of Installment Obligation; Transfer Pursuant to Divorce--Affects on Unrecognized Gain and Basis; IRC: 453B(g)(1), 1041. Tranfer 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). U.S. Residency Status, French Citizen; Green Card vs. Article 17 of U.S.-France Tax Treaty; IRC: 7701(b). U.S. Virgin Islands Matter; Erroneous Payments by a U.S. Citizen to U.S.V.I.; IRC: 6511.