We look at the case of a traveler who got bitten when she attempted to make use of the hotel to get a package picked up by a private delivery service-a package that happened to contain her petition to the Tax Court which she was filing on the last day available.  When the delivery service reported picking up the package the following day, the IRS argued that she had blown her chance to file in Tax Court--and the Tax Court agreed.

The case is Austin v. Commissioner, TC Memo 2007-11 and the materials can be downloaded at http://edzollars.com/2007-01-27_Late_Filing.pdf.

We also discuss the IRS announcement this week that 2006 returns won't be due until April 17 due to April 16 being a city holiday in the District of Columbia and its impact at the state level, and this week's release by Microsoft of the consumer version of Windows Vista and Office 2007.

The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com.

This week we look at an IRS memorandum that argues against the position taken by a taxpayer arguing that his transaction literally complies with Section 731 and 732.  The IRS argued that the transaction, which involved the partnership acquiring a residence for the partner to redeem his interest, actually represented the equivalent of a distribution of cash followed by the purchase of the house--a transaction that would have triggered a significant taxable gain.

The materials for this podcast can be downloaded from http://edzollars.com/2007-01-20_Literally_Too_Good.pdf .

The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com.

The IRS has issued Notice 2007-7 that explains the distribution provisions in the Pension Protection Act of 2006.  In the podcast, we look at some of he provisions contained in this notice that would be of special interest to advisers of closely held businesses and their owners.

The materials for the podcast can be downloaded from http://edzollars.com/2007-01-12_IRS_PPA_Notice.pdf .

The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com .

Sometimes life just doesn't seem fair.  Like when you exercise stock options from your former employer, and the stock price drops 20% from the date you told your employer to exercise the options until just a few days later.  And, even worse, at the last minute you revoked instructions to your former employer to immediately sell the shares upon exercise and instead decided to hold the shares.  In this case, the taxpayer attempted to salvage something from this by arguing that the later date was the measuring date for the compensation value since that was the date that the employer actually received the funds for the shares.

This is the story we look at in the case of Walter v. Commissioner, TC Memo 2007-2, a story that doesn't have a happy ending for the taxpayer.

The printed materials are found at http://edzollars.com/2007-01-06_Options.pdf .

The podcast is sponsored by Leimberg Information Services, on the web at http://www.leimbergservices.com .