Defensive tax return disclosures are made on Forms 8275 or 8275R, depending on whether the declared position is consistent or inconsistent with extant treasury regulations. However, the reason for filing defensive tax return disclosures goes beyond avoiding penalties associated with intentional disregard for rules and regulations. Preempting IRS deficiency notice presumptive correctness is a dominating consideration. This webcast explains.
This webcast involves Section 179 depreciation expense at the partnership level in a startup operation. Although not incorporated into this webcast, Dr. Jenkins wants to share his paper, "Why Section 179(b)(3)(A)'s Business Income Limitation Does Not Apply to Partnerships or S Corporations." The paper is currently in peer review at a university tax journal. Also, the ACPEN/BPN webcast based on this paper will be first aired during the week of . Please be sure to look for that announcement and register for the webcast.
Forms 8725 and 8725R and Intentional Disregard of Rules and Regulation Penalties
Affirmative Equitable Defenses
Preempting IRS Deficiency Notice Presumptive Correctness
*Recognize important differences in correctly filing Forms 8725 and 8725R
*Recognize equitable tax doctrine application can correctly set aside black letter law targeted benefits
*Recognize why it is important to correctly rebut the IRS presumption of correctness when filing client tax returns
*Recognize properly prepared affidavits and incorporated exhibits amount to defensive tax return disclosures that correctly reduce IRS controversies to questions of law
*Forms 8725 and 8725R
*Penalties associated with intentional disregard of rules and regulations
*Equitable Tax Doctrines
*IRS deficiency notice presumptive correctness
*Preparing defensive tax return disclosures
|Jenkins_Credentials (0.09 MB)||5 Pages||Available after Purchase|
|Defensive_Tax_Return_Disclosures_Slides (1.09 MB)||Available after Purchase|
|Important CPE Credit Instructions_READ BEFORE WEBCAST UPDATED (0.47 MB)||Available after Purchase|
|Article_Why Section179(b)(3)(A)'s Business Income Limitation Does Not Apply to Partnerships and S Corporations (0.20 MB)||Available after Purchase|
|Defensive Tax Return Disclosures_Paper (0.20 MB)||Available after Purchase|
|IRS CE Credit Request Form (0.15 MB)||Available after Purchase|
David Randall Jenkins, Ph.D., received his doctorate in accounting and a master’s in accounting with an emphasis in tax from the University of Arizona. He has taught financial, managerial, and tax accounting courses at both the graduate and undergraduate levels. Dr. Jenkins is an AACSB academically qualified business school and tax professor owing to his peer reviewed journal article publications. His company, Algorithm LLC (algorithm-llc.com), is an IRS Approved Continuing Education Provider. Dr. Jenkins may be contacted at firstname.lastname@example.org.
This webcast is an intermediate continuing education webcast.
It is assumed the webcast participant has achieved basic understanding of the following: Equitable tax doctrines, Penalties associated with intentional disregard of rules and regulations, & Issues involving IRS deficiency notice presumptive correctness
*Enrolled Retirement Plan Agents
*Self-directed Retirement Plan Fiduciaries, Custodians, and Administrators
*Self-directed Retirement Plan Account Holders
*Tax Return Preparers
David Randall Jenkins
Business Professionals' Network, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org
Group Internet Based
Please wait ...