The Tax Court held that it lacked jurisdiction over a request for Sec. 6015(f) equitable relief that was based on the same facts and grounds for relief as an earlier request that had been denied by the IRS. Facts Judith Barnes was married to Nathan Genrich. On their joint return
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TOPICS
Individuals
Tax Planning for Elderly Clients
With the rapid increase in the number of elderly clients, tax practitioners will need to become familiar with the special issues that affect tax compliance and planning for the elderly.
Planning Opportunities with the Sec. 121 Partial Exclusion
The partial exclusion of gains on the sale of a primary residence continues to be an attractive benefit for taxpayers.
Academic-Based VITA Programs
VITA programs sponsored by accounting programs provide valuable, free tax services to their communities.
Avoiding the Self-Rental Trap
This item gives a general background of the passive activity rules and the self-rental provision and addresses the consequences of a sale of an operating company when the self-rental property is retained.
Tax Consequences of the Rush for Natural Gas in the Appalachians
This item provides an overview of some areas of taxation that taxpayers and their advisers must consider to ensure the most favorable terms if their clients are approached by an energy company seeking a land lease and royalty agreement.
The Importance of CPAs Supporting VITA: One CPA’s Experience
It is important that CPAs provide their expertise to ensure that VITA provides the level of required service and quality of return preparation.
Getting the Most from Individual Charitable Contributions
This article discusses the issues involved in determining whether a charitable contribution is deductible, what the amount of a contribution is, and when and how much of a contribution is deductible.
IRS Intensifies Focus on Worker Classification
As the IRS intensifies its scrutiny of worker classification, businesses may want to take a fresh look at how their policies, procedures, and documentation around engaging independent contractors might withstand IRS review.
Government Loses Son of Boss Tax Shelter Case
In a rare tax shelter loss for the IRS, a federal district court has allowed a taxpayer to offset income with losses from a “son of boss” transaction.
Taxpayer Must File Jointly to Qualify as Innocent Spouse
The Ninth Circuit has held that to be eligible for innocent spouse relief under Sec. 6015, a taxpayer must have filed a joint return with his or her spouse and that Sec. 6015’s equitable relief provision also requires that a joint return had been filed.
Converting a Residence to Rental Property
A decision to convert to rental should consider factors such as the taxpayer’s marginal tax rate, availability of excluding gain from the sale of a personal residence, expected growth rate of the rental property, length of time the house will be rented before being sold, cash flow from renting, effect of the passive activity rules, and rate of return on other invested funds.
IRS Previews Sec. 529 Plan Anti-abuse Regs.
The IRS has announced that because of the potential for the abuse of Sec. 529 accounts, it intends to issue proposed regulations and is requesting written comments from tax practitioners on the rules it is contemplating.
Alternative Motor Vehicles and the AMT
Effective for 2006, Congress provided a credit for alternative motor vehicles in an effort to reduce U.S. reliance on fossil fuels and imported oil.
Compensation Issues for Self-Employed S Corp. Owners
This item discusses how reporting a higher wage can actually maximize long-term profits for the owner-employee of an S corporation.
The Mortgage Forgiveness Debt Relief Act of 2007
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.
Defendant May Claim Improper Diversions of Corporate Funds Were Returns of Capital
The Supreme Court, reversing the Ninth Circuit, held that where a taxpayer is charged with criminal tax evasion related to funds he diverted from a corporation for his own use, the taxpayer may claim as a defense that the funds he received were a nontaxable return of capital without proving that they were intended as a return of capital at the time the diversion occurred.
Federal, State, and Local Tax Incentives for Environmental Remediation Costs
This item provides a high-level overview of the most common federal, state, and local tax incentives and a brief update of the federal rules regarding the expensing of environmental remediation costs.
Financial Literacy: University-Focused Activities
A well-planned university-based financial literacy effort can benefit students and communities beyond the campus.
IRS Provides Sec. 1031 Personal Use Safe Harbor for Dwellings
The IRS has provided a safe harbor, under which it will not challenge whether a dwelling unit qualifies as held for productive use in a trade or business or for investment purposes under Sec. 1031, governing like-kind exchanges.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
