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Taxpayers Do Not Have Standing to Challenge Parsonage Exemption

The Seventh Circuit held that an ­atheist group and two of its members did not have standing to challenge the Sec. 107(2) parsonage exemption because the members had never actually tried to claim the exemption and had therefore suffered no injury.

Substantiating Expenses: All or Nothing

Without proper substantiation, no deduction is allowed for a Sec. 274(d) expense, even if the court believes that a legitimate expenditure was made.

Land Sales: Is the Taxpayer Considered a Dealer or Investor?

Recent court decisions are reminders that land may not always be a capital asset that gives rise to a capital gain when sold. Land may also be held for sale to customers in the ordinary course of business, in which case gain on the sale of the land will be ordinary income.

Valuing Partnership Interests Acquired in Exchange for Services

This column addresses the rules that currently govern the receipt of a partnership interest in exchange for services. Practitioners should be aware that proposed regulations and Notice 2005-43 provide new rules and new safe-harbor provisions that will apply to the receipt of a partnership interest by a service partner when the regulations are finalized.

Capital Gains Treatment for Patent Royalties Denied

The Tax Court held that a taxpayer had not transferred all substantial rights in patents to an unrelated corporation because he was in control of the corporation; therefore, he was not entitled to capital gain treatment under Sec. 1235 for royalties on the patents that the corporation paid to him.

Minimum Essential Coverage, Other Health Care Reform Guidance Issued

The IRS released health care guidance, including final regulations on minimum essential coverage, a list of hardship exemptions from individual shared-responsibility penalty, and indexed adjustments for certain calculations under the premium tax credit.

IRS Fills in Details of One-a-Year IRA Rollover Rule

The IRS clarified how the recently announced change in how it interprets the statutory one-rollover-per-year rule for IRAs will affect 2014 rollovers and how the rules will apply starting in 2015.

Forfeited Gambling Winnings Not Included in Income

The IRS advised that gambling winnings that a taxpayer surrenders to a state as part of a program intended to help treat gambling addiction do not have to be reported by a casino to the taxpayer on Form W-2G and are not includible in gross income by the taxpayer.

Innocent Spouse Relief Under Rev. Proc. 2013-34

The IRS’s new revenue procedure revised the rules for taxpayers who request equitable relief from joint and several tax liability under Sec. 6015(f) or from tax liability arising from the operation of community property laws under Sec. 66(c).