Mon, 28 April 2008 This week we follow the continuing saga of the self-employment tax and qualified joint venture that we've been following since the early part of this year. This week we analyze CCA 200816030 issued by the IRS that outlines the "new improved" IRS position on self-employment tax and the Qualified Joint Venture election under §761(f).The materials for the podcast are available at http://www.edzollars.com/2008-04-28_SEandQJV.pdf . The podcast is sponsored by Leimberg Information Services, located at http://www.leimbergservices.com . Comments[0] |
Sun, 20 April 2008 The issue of whether §7502(c) provides the exclusive means to prove timely filing of a document by a taxpayer is addressed yet again by the courts--and what the Third Circuit had to say, the IRS didn't like hearing. In the case of Philadelphia Marine Trade Ass'n.-Int'l Longshoremen's Association Pension Fund et al. v. Commissioner, 2008 TNT 74-16 the Third Circuit held that the reports of the death of the common law mailbox rule were, in the words of Mark Twain, greatly exaggerated. That places the Third Circuit in the same camp with the Eighth, Ninth and Tenth Circuits, and opposed to the positions of the Second and Sixth Circuits.The materials for this podcast are located at http://www.edzollars.com/2008-04-21_Mailbox.pdf. The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com. Comments[0] |
Wed, 16 April 2008 After a hiatus at the end of tax season, we return with a new show dealing with an issue of whether a payment to a person was compensation income or a gift. The case in question is the case of Larsen v. Commissioner, TC Memo 2008-73.The materials for the podcast are at http://www.edzollars.com/2008-04-16_GiftorComp.pdf. We also briefly discuss an interesting episode of a podcast I found on small service business operating issues at a place you might not look--check out http://macbreaktech.com/63/making-mac-your-business/ for an interesting listen that really isn't very MacIntosh (or even computer) centric--just a general discussion of issues facing small service businesses. The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimberservices.com . Comments[2] |

This week we follow the continuing saga of the self-employment tax and qualified joint venture that we've been following since the early part of this year. This week we analyze CCA 200816030 issued by the IRS that outlines the "new improved" IRS position on self-employment tax and the Qualified Joint Venture election under §761(f).