October’s most interesting case involved a limited liability company that took losses in excess of basis flowing from a lower-tier partnership. IRS discovered the error after it was too late to correct the applicable returns. Does the LLC need to reduce basis in the lower tier partnership by those losses? The Tax Court said that it does. We also examine whether Collection Due Process appeal rights apply to FBAR penalties. The Tax Court noted that they do not.
Learning Objectives:
- List the latest regulations, rulings, and pronouncements from the IRS
- Summarize the most recent decisions out of the Tax Court and federal district courts around the country
David De Jong, CPA
Stein Sperling Bennett De Jong Driscoll PC
Principal
[email protected]
(301) 340-2020
As chair of the firm’s tax practice group, David helps businesses and individuals with a broad range of tax planning and controversy matters, estate planning, business transactions, and valuations. A CPA with a Master of Laws in Taxation from Georgetown University Law Center, he is accredited in estate planning by the National Association of Estate Planners and Councils and in business valuation by both the American Institute of Certified Public Accountants and the National Association of Certified Valuators and Analysts. With over 35 years of experience, David brings a high level of expertise, sound judgment, and personal attention to help solve his clients’ tax, estate, and business matters.
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