Recent events have drawn attention to the disallowance of deductions where allowing the deductions would violate public policy. This article discusses the disallowance of deductions under Sec. 162 and Sec. 165 for public policy reasons.
May 2011 - The Tax Adviser
procedure & administration
Schedule UTP: IRS Mandates Disclosure of Uncertain Tax Positions
This article explores the requirements of Schedule UTP, discusses modifications to the IRS’s policy of restraint pertaining to tax reconciliation workpapers, and suggests how to avoid the inadvertent waiver of the work-product privilege for documents relating to uncertain tax positions.
procedure & administration
Regulation of Tax Return Preparers
To improve the oversight of tax preparation by paid tax preparers, the IRS has established a registration, examination, and continuing education regime for paid tax preparers. This article discusses the general requirements under the regime and the specific rules and exceptions to the rules for CPAs.