IRS Field Attorney Advice 20061701F, (April 28, 2006), which may not be used or cited as precedent, considered whether accrual basis taxpayers can deduct
employment taxes on vacation/bonus pay accrued at year-end, but not paid until the next year.
To put this in perspective, consider expensing, where the entire purchase price is immediately deducted
. With expensing, the government essentially becomes a partner.
On his return, J deducts
his attorneys' fees under Sec.
If a taxpayer uses a timeshare unit and it is not rented out (or held out for rent), he or she could deduct
property taxes on Schedule A, under Sec.
According to revenue procedure 94-27, effective for taxable years beginning after December 31, 1990, home buyers may deduct
mortgage points currently even if the points are paid by the seller of the property--as long as they reduce the property's cost basis by the amount of the seller-paid points.
If the customer does not use the voucher, T recognizes as earned revenue the previously deducted
estimated incremental cost (e.g., the percentage of the face value) on expiration of the voucher (one year from issuance), and includes that amount in gross income for Federal income tax purposes.
Recently, in Ingram Industries, Inc., TC Memo 2000-323, the Tax Court held that a towboat operator could currently deduct
costs associated with periodic or cyclical service and maintenance of its towboat engines, in spite of the IRS's argument that its engine maintenance procedures were equivalent to overhauls.
On an amended Form 5500, Annual Return/Report of Employee Benefit Plans (with 100 or more participants), and amended Schedule B, the employer reported the $41,848,000 as contributions for the plan year ended June 30,1984, and deducted
the entire $117,291,000 on its 1984 return.
351 exchange could deduct
payments for a vacation pay liability assumed in the exchange.
In Boyd Gaming Corp.,(22) the Tax Court ruled that a casino can deduct
100% of the cost of meals provided free to employees if such meals meet the de minimis fringe benefit exception of Sec.
Generally, a partner who does not materially participate in a partnership's trade or business activity is considered to be passive with respect to the activity, thereby potentially limiting his ability to deduct
losses from the activity.
The issue was whether Ford could deduct
the full amount of future payments under 1980 settlement agreements for tort liabilities in the tax year the agreements were executed.