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: Sales and Exchanges Alternative Minimum Tax; ACE Adjustment--Installment Sales; IRC: 56(g)(4)(D)(iv), 453, 336(a). Amortization of Intangibles; Covenant-Not-To-Compete, Use of "Likeness" of Individual; IRC: 197. Bargain Sale to Charity; Issues Related to Bargain Sale to Charity of Principal Residence; IRC: 170, 1001, 1011. Basis Issues; Disputed Contract Amounts--Inclusion in Basis; IRC: 1012, 1231. CFC Stock, Sale of; Avoidance of CFC Rules; IRC: 1248. Charitable Contributions; Charitable Contributions of Appreciated Property as Sale or Exchange; IRC: 1001, 170. Closely-Held Corporate Stock; Tax-Free Rollover of Gain from Stock Sale; IRC: 1044, 1001. Contribution of Appreciated Property; Contribution of Property Subject to a Prearranged Sale; IRC: 1011(b), 1001. Corporate Liquidation; Proper Corporate Level Treatment of Shareholder Loan; IRC: 61(a)(12), 118, 108. Cross-Collateralization Issue; Eligibility to Off-Set Loss or Diminish Gain; IRC 61, 1001, 1012. Development Activities; Dealer Status; IRC: 1221. Double Deductions; Charitable Deduction for Waste and By-Products; IRC: 1011 and 1012; 170 and 162. Foreclosure; Foreclosure on Seller-Financed Debt; IRC 1038. Foreclosure; Validity of "Rescission of Foreclosure" Agreement; IRC: 1001. Gift of Limited Partnership Interest; Various Issues; IRC: 1001, 1041. Installment Liquidation; S Corporation Installment Liquidation--Time Period Limitations; IRC: 453(h), 453(B)(h), 331. Installment Obligation; Effects of Foreclosure; IRC: 1001, 1038. Installment Obligations; Effect of Modifications to Installment Note; IRC: 1001, 453, 453B. Installment Sales; Allocation of Installment Proceeds Among Classes of Assets Sold; IRC: 453. Installment Sales; Annuity Contract as Payment in Year of Sale; IRC 453 Installment Sales; Foreclosure by Superior Lienholder as Disposition of Junior Installment Note; IRC 453B Installment Sales; Installment Sales--Purchase Price Adjustments; IRC: 453B(a), 1231. Installment Sales; Installment Sale of Accounts Receivable; IRC 453. Installment Sales; Installment Sale Reporting; IRC: 453. Installment Sales; Related Party Rules; IRC 453. Installment Sales; Self-Canceling Installment Notes (SCIN's); IRC: 691(a)(2), 691(a)(5), 453B(f). Installment Sales; Self-Canceling Installment Notes; IRC: 102, 453B, 61(a)(12). Installment Sale to Controlled Partnership; Related Party Installment Sales, Recharacterization of Gain on Sale Between Related Parties; IRC: 1239, 453(g), 267. Liquidations; Installment Sale in Conjunction with Liquidation; IRC: 336, 331, 453. Original Issue Discount; OID on Contingent-Payment-Only Sales; IRC 1275. Partnership Disguised Sale Rules; Applicability of Partnership Disguised Sale Rules; IRC: 707(a), 721, 752. Partnership Interests; Acquisition of Partnership Interests; IRC: 708(b)(1)(B), 704, 752, 482, 267. Partnership Property, Sale of; Effect of Related Parties on Installment Sale and Character of Income; IRC: 1231, 707(b), 453(g), 731. Partnership Terminations; Recapture of Negative Capital Account; Termination of Partnership; IRC: 708(b)(1)(B). Purchase Price Allocation; Allocation of Cost to Law Firm Contingent Fee Case Inventory; IRC 1001, 165, 1060, 338(b)(5), 197. Redemption; Employee Buyout of Sole Shareholder; IRC: 302. Related Party Losses Disallowed; Loss Property Sold to Trust; IRC 267. Sale of Assets for Restricted Stock; Timing of Income Recognition; IRC 1001. 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. Tax Benefit Rule/AMT; Tax Benefit Rule Gain Adjustment for Prior AMT Items; IRC: 58(h), 59(g). Technical Terminations; Buyout Resulting in a One-Member LLC; IRC: 754, 708(b)(1)(A), 732(c), 732(d), 1231, 743(b). Timing of Income Recognition; Lease with Option to Purchase; IRC: 1001, 1234. Transfer of Assets; Effects of Transfer of Assets from Corporation to Partnership; IRC: 501(c)(3), 1060, 168(f)(5)(B)(iii). Transfer of Installment Obligation; Transfer Pursuant to Divorce--Affects on Unrecognized Gain and Basis; IRC: 453B(g)(1), 1041.