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TOPICS / PROCEDURE

Special Deadline: Filing Amended Returns Reporting Tax Due Within 60 Days of Assessment Limitation

When a taxpayer files an amended return reporting additional tax within 60 days before expiration of the assessment limitation period, Sec. 6501(c)(7) provides that the period within which the IRS can assess the additional tax does not expire before the 60th day after the day on which it receives the amended return. This extension of the assessment limitation period applies only to the additional tax reported on the amended return.

Final Rules Govern Basis Reporting

The IRS issued final and temporary regulations that provide rules for brokers to report bond premium and acquisition premium as well as govern information reporting of transactions involving debt instruments and options, including the reporting of original issue discount on tax-exempt obligations, the treatment of certain holder elections for reporting a taxpayer’s adjusted basis in a debt instrument, and a new requirement to report transfers of Sec. 1256 options and debt instruments.

Tax Reform: Five Priorities to Remember

As a new Congress begins a fresh look at tax reform, the AICPA intends to stay engaged in the process and advocate on issues of particular interest to CPAs. Five areas deserve strong consideration in tax reform.

Former Partner Liable for Trust Fund Penalty

A taxpayer who asserted he was no longer a partner in a business during the periods at issue was nevertheless held to be a responsible person and liable for the 100% penalty for failure to pay over withheld employment taxes.

Final Regulations Amend Broker Basis Reporting Requirements

The IRS issued final and temporary regulations that provide rules for brokers to report bond premium and acquisition premium as well as govern information reporting of transactions involving debt instruments and options.

Tax Court Reforms Statute-of-Limitation Extensions

The Tax Court found that the IRS and the taxpayers made a mutual mistake on Forms 872, Consent to Extend the Time to Assess Tax, regarding the tax years for which the statute of limitation on assessment was being extended and reformed the forms to apply to the years that the IRS and the taxpayers intended to extend.

Congress Enacts Last-Minute Extenders for 2014

The Senate passed a bill to retroactively extend more than 50 expired tax provisions through 2014, by a vote of 76-16 on the evening of Dec. 16. The extender bill passed the House of Representatives on Dec. 3, and was signed by President Barack Obama on Dec. 19.