Tax Returns, Examinations, and 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: Professional Tax Research Material, Resources, and Consulting

The Tax Resource Group Memo Library
Category: Tax Returns, Examinations, and IRS Procedure

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

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

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

Collections; Limitation on Collections; IRC: 6502, 6335(a), 6503(h).

Community Property; Separated Spouses, Allocation of Income; IRC: 66(a).

Examinations; Burden of Proof--Deduction Case IRC: 162.

Examinations; Repetitive Examinations/Opening Closed Cases; IRC 7605(b).

Examinations; Securing 9100 Relief; IRC: 9100.

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

Examinations; Statute of Limitations for Partnership Examinations; IRC: 6229, 6231.

Extension of Time to File Returns; Extensions for Divorcing Taxpayers; IRC: 6081.

Filing Requirements; Virgin Islands--Former Resident; IRC: 932(c).

Jointly Owned Property; Electing Out of Partnership Provisions; IRC: 731, 732, 168(i)(7).

Net Operating Loss Carryback; Election to Forgo NOL Carryback on Amended Return; IRC: 172(b)(3).

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

Nonresident Alien Limited Partners, Taxation of; Various Issues; IRC: 1231, 1441, 871, 875(1), 6012.

Partnership; Withholding Requirements for Partnership with Foreign Partners; Filing Requirements U.S. Partners; IRC: 704, 871, 1445, 1446, 875.

Partnership Losses; Mitigation of Statute of Limitations; IRC: 1311 through 1314.

Payments; Allocation of Payments to IRS.

Private Foundation; Estimated Taxes; IRC: 6655.

Retention of Return Information by Tax Preparers; Length of Time Preparers Must Keep Information; IRC: 6107.

Revenue Ruling 65-80; Section 331 Treatment; Effect on Failure to File Form 966; IRC 7203.

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

Section 911 Election; Late Election; IRC: 911, 9100.

Statute of Limitations; Amended Individual Return to Account for S Corporation Filing; IRC: 6501.

Statute of Limitations; Corporate Understatement of Gross Earnings; IRC: 6501(e).

Statute of Limitations; NOL Carryback Claim, Time Limitation for Filing; IRC: 6511(d)(2)(A).

Tax Return Election; Termination of Section 444 Election; IRC: 444.

Tax Returns; Due Date--S Corporation Electing Non-Calendar Tax Year; IRC: 444, 7519.

Tax Returns; Form 1041-A for Split-Interest Trusts; IRC: 6034, 4797(a)(2).

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).

U.S. Virgin Islands Matter; Erroneous Payments by a U.S. Citizen to U.S.V.I.; IRC: 6511.