Individuals

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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: Real Estate Abandonment Loss; IRS Denial of Abandonment Loss Treatment; IRC: 165. Basis Issues; Disputed Contract Amounts--Inclusion in Basis; IRC: 1012, 1231. Capital Gain; Subdivided Real Estate; IRC: 1221. Carrying Costs, Unproductive Property; Capitalization vs. Deduction of Expenses; IRC 266. Depreciation; Placed in Service Issues, Staged Completion of Building; IRC: . Development Activities; Dealer Status; IRC: 1221. Fixture--Definition of; Storage Tanks as Real Property; IRC: 460. Foreclosure; Foreclosure on Seller-Financed Debt; IRC 1038. Foreclosure; Validity of "Rescission of Foreclosure" Agreement; IRC: 1001. Foreclosure Against Recourse Debt, Discharge in Bankruptcy; Effect of Foreclosure and Subsequent Discharge; IRC: 61(a)(12), 108. Installment Obligation; Effects of Foreclosure; IRC: 1001, 1038. Installment Sales; Installment Sales--Purchase Price Adjustments; IRC: 453B(a), 1231. Involuntary Conversions; Involuntary Conversions--Nature and Timing of Replacement Property; IRC: 1033, 280B, 1231. Joint Property; Basis Issues; IRC: . Leasehold Improvements; Abandonment of Leasehold Improvements; IRC 267. Like-Kind Exchange; REIT Stock in a Section 1031 Exchange; IRC 1031. Like-Kind Exchange; Various Issues; IRC: 1031, 1250, 1231, 291. Part-Gift, Part-Sale of Home; Various Issues; IRC: 1034, 121, 2501. Principal Residence, Sale of; Cost of Replacement Residence; IRC: 1034. Principal Residence, Sale of; Multiple Replacement Properties; IRC: 1034(c)(4). Principal Residence, Sale of Partial Interest; Effect on Section 1034 Treatment; IRC: 1034. Property, Sale of; Comments on Suggestions to Shelter Property with Very Low Tax Basis; IRC: . Real Estate Dealer Status; Reclassification of Rehabilitation Activity as a Trade or Business Rather than an Investment Activity; IRC: 1221. Real Estate Dealer Status; Taxpayer Stroke as Evidence of Change of Intent to Hold Property for Sale to Customers; IRC: 1221. Rehabilitation Credit; Issues Related to Certified Historic Structure; IRC: 49(a)(1). Rental House, Sale of; Exclusion of Gain; IRC: 121, 1034. 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. Residence, Sale of; Interaction of Section 121 and Installment Sale; IRC: 121, 453B(c), 691(a), 453(d). Section 108(e)(2); Various Issues; IRC: 108(e)(2), 163(d)(5)(A), 469(e)(1). Section 1031 Exchanges; Boot; IRC: 1031. Section 1031 Exchanges; Debt in Section 1031 Exchanges; IRC: 1031. Section 1031 Exchanges; Partnership Property, Replacement Property--Change of Intent; IRC: 1031. Section 1031 Exchanges; Property Received in Exchange--Requirements for Purchase Price and Debt Restrictions; IRC: 1031. Section 1031 Exchanges; Related Party Section 1031 Exchange Issues; IRC: 1031. Section 1031 Replacement Property; Land Improvements Exchanged for Land; IRC: 1031, 1033(g). 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. Temporary Rental of Residence; Passive Activity Loss Provisions vs. Rental Use of Residence Rules; IRC: 469, 280A. Timing of Income Recognition; Lease with Option to Purchase; IRC: 1001, 1234. Uniform Cost Capitalization; UNICAP on Property Held for Investment; IRC 263A.