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Gambler’s Luck Turns in Second Trip to Tax Court

A taxpayer who consistently lost money playing the slots at two casinos in California was found not to have an actual and honest profit objective and could not deduct her gambling losses on Schedule C.

Earnout Restriction Causes Substantial Risk of Forfeiture

The Tax Court held that sections of a restricted stock agreement and an employment agreement read together constituted an earnout restriction that might create a substantial risk of forfeiture for stock transferred to an employee.

Earnout Restriction Causes Substantial Risk of Forfeiture

The Tax Court held that sections of a restricted stock agreement and an employment agreement read together constituted an earnout restriction that might create a substantial risk of forfeiture for stock transferred to an employee.

0.9% Medicare Surtax Final Regulations Issued

Regulations contain guidance for employers and individuals on the implementation of the tax, including the requirement to file a return reporting the tax, the process for employers to make adjustments of underpayments and overpayments of the tax, and the processes for employers and employees to file claims for refund for an overpayment of the tax.

3.8% Net Investment Income Tax Regulations

The IRS issued final and proposed regulations giving guidance on the application and computation of the 3.8% net investment income tax imposed by Sec. 1411.

Current Developments for Straddle Transactions

This item provides a brief background and summary of IRS regulations clarifying whether an obligor’s debt could be part of a straddle and the treatment of prestraddle gain or loss related to a position that is part of a “mixed straddle”.