IRS Action On Decision 2017-4: Scott Singer Installations, Inc. v. Commissioner

Joe Nagel Website PictureThe IRS recently acquiesced in result only in the case of Scott Singer Installations v. CIR, TC Memo 2016-161. Mr. Singer had loaned his wholly owned corporation funds to stay afloat during hard times. The corporation made advances to Mr. Singer for payment of certain personal expenses. The taxpayer contended the advances for personal expenses were repayment of loans whlle the IRS argued they were compensation. The court found the payments were in fact loans because the taxpayer had acconted for them as such on his personal returns and it concluded there was a general expectation of repayment of amounts loaned. This case again shows the importance of documenting related party loans and properly accounting and reporting them. Loans should be documented, bear adequate interest, and collateralized. The IRS will only respect a loan as such if the taxpayer does as well.

For more information regarding this or any ther tax related concern please contact us at 404-255-7400 or

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IRS Notice 2017-29: Disclosure Deadline Extended for Participants in Syndicated Conservation Easements

Doug Image CroppedThe IRS recently issued Notice 2017-29, which extends the deadline for participants in syndicated conservation easements to make their discosure (as required in Notice 2017-10),  from June 21, 2017 to October 2, 2017. Notably, it does not extend the May 2nd deadline for material advisors and participants under Treas. Reg. 1.6011-4(e)(1). If you have questions about the new IRS scrutiny on conservation easements and the listed transaction/tax shelter rules, we can help. For more information please contact us at 404-255-7400 or

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IRS Tax Tip 2017-51: Important Facts about Filing Late and Paying Penalties

DSC00052The IRS recently issued the attached Tax Tip for Late Filing Penalties. If you have late filing or other penalties, we may be able to help. For more information please contact us at 404-255-7400 or

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IRS Revenue Procedure 2017-33: Bonus Depreciation

Joe Nagel Website PictureIn this document, the IRS provides guidance on recent changes to Section 179 expense and bonus depreciation. Importantly, the 179 expense is increased for inflation to $510,000 and bonus depreciation is 50% for 2017 but decreases to 40% in 2018 and 30% in 2019. The latter change obviously provides a tax advantage for businesses to place qualifying prorperty into service in 2017 rather than 2018.  For more information regarding this document or any other tax concern, please call us at 404-255-7400 or

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IRS Tax Tip 2017-74: Debt Collection: Private-Sector Collection Agencies

Joe Nagel Website PictureThe IRS is beginning the process of transferring the overdue tax debt of a small group of taxpayers to private debt collectors. Importantly, the private debt collectors are not entitled to take enforcement action (only an IRS agent can do so). While the program is currently very small, it could portend the future if successful:

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IRS Tax Tip 2017-82: New Filing Deadline Now Applies to Foreign Account Reports

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The IRS recently released the attached notice as a good reminder of the filing/disclosure requirements for those taxpayers with foreign assets, including FATCA and FBAR compliance:

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IRS Tax Tip 2017-26: Medical and Dental Expenses May Impact Your Taxes

business lawHere is what you need to know if you are claiming medical/dental expenses as itemized deductions:

Medical expenses can trim taxes. Keeping good records and knowing what to deduct make all the difference. Here are some tips to help taxpayers know what qualifies as medical and dental expenses:

Itemize. Taxpayers can only claim medical expenses that they paid for in 2016 if they itemize deductions on a federal tax return.
Qualifying Expenses. Taxpayers can include most medical and dental costs that they paid for themselves, their spouses and their dependents including:

• The costs of diagnosing, treating, easing or preventing disease.
• The costs paid for prescription drugs and insulin.
• The costs paid for insurance premiums for policies that cover medical care.
• Some long-term care insurance costs.

Exceptions and special rules apply. Costs reimbursed by insurance or other sources normally do not qualify for a deduction. More examples of what costs taxpayers can and can’t deduct are in IRS Publication 502 , Medical and Dental Expenses.

Travel Costs Count. It is possible to deduct travel costs paid for medical care. This includes costs such as public transportation, ambulance service, tolls and parking fees. For use of a car, deduct either the actual costs or the standard mileage rate for medical travel. The rate is 19 cents per mile for 2016.
No Double Benefit. Don’t claim a tax deduction for medical expenses paid with funds from your Health Savings Accounts or Flexible Spending Arrangements . Amounts paid with funds from these plans are usually tax-free.
Use the Tool. Taxpayers can use the Interactive Tax Assistant tool on to see if they can deduct their medical expenses.

Taxpayers should keep a copy of their tax return. Beginning in 2017, taxpayers using a software product for the first time may need their Adjusted Gross Income (AGI) amount from their prior-year tax return to verify their identity. Taxpayers can learn more about how to verify their identity and electronically sign tax returns at Validating Your Electronically Filed Tax Return .

For more information regarding this or any other tax concern please contact Hoffman & Associates at 404-255-7400 or

2017 IRS Tax Tip: Avoid Overpaying User Fees for Your Voluntary Correction Program Submission

wins-imageFor taxpayers who have filed or intend to file under the voluntary correction program, the IRS has recently issued this helpful notice concerning reduced user fees for such applications under certain circumstances. See Revenue Procedure 2017-4 for more information on the determination of applcable user fees for the voluntary compliance program. Should you have any questions or concerns regarding this information please feel free to give us a call at 404-255-7400 or email us at

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