Federal Tax Update: Western Wisconsin Week

https://vimeo.com/388726525

https://www.currentfederaltaxdevelopments.com/podcasts/2020/2/1/2020-02-03-western-wisconsin-week  

 

This week we look at:

• Special agent in charge of Los Angeles CID talks about their potential use of the virtual currency question on Schedule 1, Form 1040.
• Taxpayer wins on claim LLC was not a sham, but finds the result is actually worse when court rules amounts paid to law firm were start-up expenses under §195 TAM rules that taxpayer did not have an intangible related to synergistic benefits that could be written off.
• Taxpayer could not use claim of right provision under §1341(a) to claim a deduction related to gain recognized in prior year when trustee of grantor sold stock that trustee was barred from selling by the trust agreement.
• IRS and taxpayer agree that a regulation on the books since 2001 mandates a result different from what the court had arrived at when agreeing with IRS position on §7502(a) and late filed returns asserted originally in the case.