We once again revisit the Cohan rule, but this time in the context of a much larger taxpayer than we normally look at, in the case of Tyson Foods, Inc and Subsidiaries vs. Commissioner, TC Memo 2007-188.  The taxpayer's was attempting to argue, based on Cohan rationalization, that they should be able to depreciate a $2,000,000+ debit remaining on their books after making an agreed upon adjustment under IRS exam.  The IRS (and eventually the Tax Court) did not agree that such a treatment should be allowed.

The materials for the case are at http://www.edzollars.com/2007-07-21.pdf .

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

Equitable ownership of a home can grant a taxpayer a deduction for mortgage interest and taxes even when the taxpayer is not the legal owner.  While the taxpayer in the case of Nair v. Commissioner, TC Summary Opinion 2007-116, did not have such ownership, the opinion does outline the requirements a taxpayer would need to demonstrate to have such equitable ownership.

As well, Mr. Nair's failed attempt to obtain a casualty loss deduction also offers some insights into the issue of establishing basis for items that are involved in a casualty loss deduction.

The materials for the podcast can be downloaded from http://www.edzollars.com/2007-07-15.pdf.

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

We finish up the look at §6662, this time looking at the substantial understatement penalty, as well as the exceptions to this penalty.

The material for this week's podcast can be downloaded from http://www.edzollars.com/2007-07-09_Substantial_Understatements.pdf.

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

For Independence Day we take a look at a new set of standards released by the American Institute of CPAs' Consulting Services Executive Committee that will take effect for engagements entered into after January 1, 2008.  The Statement on Standards for Valuation Services No. 1, Valuation of a
Business, Business Ownership Interest, Security, or Intangible
Asset can have an impact on tax practice where the value of an asset covered by this standard has an impact on a tax issue. 

CPAs will need to be aware of when this standard may become applicable and the options when that might take place.  Those that work with CPAs in tax practice, include tax attorneys who are working with the client's CPA, need to be aware of this change and the impact of this standard on both what the CPA can do and the cost of having the CPA perform certain functions.

The materials for this podcast can be downloaded from http://www.edzollars.com/2007-07-04_SSVS.pdf .

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

Given that in both the changes to Circular 230 paragraph 10.35 back in 2005 and the recent revisions to Section 6694, it seems appropriate to review the penalties that can be imposed on a taxpayer under this section, a section whose outlines of level of comfort in a position have borrowed in revising both of those provisions. 

This week we look at §6662(b)(1)'s negligence and disregard of rules and regulations penalty, planning to look next at the substantial understatement provisions of §6662(b)(2). 

The materials for this podcast can be found at http://www.edzollars.com/2007-06-29_Client_Side_Penalties.pdf .

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