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Violation of Public Policy and the Denial of Deductions

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.

Day-Trading Losses Are Dissipation of Assets

The Tax Court held that a taxpayer’s losses from a period of day-trading activity constituted a dissipation of assets that the IRS could take into account in determining whether to accept the taxpayer’s offer in compromise.

A Blended Approach to Teaching Tax Writing Skills

This column describes how a group of tax professionals, one of whom is also an adult learning specialist, collaborated with a writing consultant to create a distinctive training experience for CPAs on how to write for the profession.

Contribution Deduction Denied for Gifts to Family Public Charity

The Tax Court denied a taxpayer’s claim for a deduction for a contribution of stock to a charitable foundation that the foundation used to set up a family public charity account in which the taxpayer’s contribution was segregated for investment and future distribution at the taxpayer’s discretion.

The Changing Landscape of Conservation Easements

Conservation easements are some of the most effective tools available to ensure permanent conservation of privately held land in the United States. This article discusses federal income tax benefits from the creation of conservation easements.

Required Minimum Distribution Alternatives for IRA Beneficiaries

This article discusses the distribution options available to IRA beneficiaries, with an emphasis on opportunities to control the timing of the distribution period and actions that must be taken on a timely basis to achieve the desired outcome.

Making Gifts to Minors

This column discusses the advantages and disadvantages of gifting under the Uniform Gifts to Minors Act or the Uniform Transfers to Minors Act and in what kinds of situations each should be used.

Medical Residents Subject to FICA

The Supreme Court held that individuals in medical residency programs at teaching hospitals are subject to FICA on the stipends they receive for the work they perform while participating in the medical residency programs.

Deadline for Equitable Innocent Spouse Claims Again Upheld

The Third Circuit held that the two-year deadline in Regs. Sec. 1.6015-5(b)(1) for filing an equitable innocent spouse relief claim under Sec. 6015(f) is valid because it is a permissible interpretation of the statute.