May 2008 - The Tax Adviser

Practitioners can use the qualified offer to get a case resolved, or hopefully at least reviewed, within 90 days, and can use the qualified offer to impose administrative and litigation costs on the government when it refuses to accept a reasonable settlement offer

In response to the subprime mortgage crisis, the Mortgage Forgiveness Debt Relief Act of 2007 excludes from income the discharge of qualified principal residence indebtedness. Its discharge provisions are temporary and apply to discharges during 2007, 2008, and 2009.

This article addresses the opportunity to claim a Sec. 199 deduction when a business is sold in an asset sale or in a stock sale that is treated as an asset sale under a Sec. 338(h)(10) election.

Circular 230 outlines the duties and restrictions relating to practice before the IRS and the rules regarding disciplinary proceedings for violations. Final regulations issued in 2007 made many changes to Circular 230.