The Tax Adviser

Issue Date: 10/01/1996

In This Issue

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1. Allocation of nonrecourse debt under the three-tier sec. 752 allocation... Facts: Lois and Clark are forming The Daily Planner Partnership, which they will own equally. Lois contributes $40,000 cash and Clark contributes depreciable property with ... (PERIODICAL ARTICLE) 2. Favorable court decision on FTC carrybacks may necessitate immediate... On May 24, 1996, the Court of Federal Claims rendered a tax payer favorable opinion in Fluor Corporation. The court ruled that when a foreign ... (PERIODICAL ARTICLE) 3. Internal IRS guidelines on requests for field service advice and technical... Recent internal IRS guidelines explain to IRS field personnel the criteria for requesting field service advice (FSA) and technical advice (TA) from the IRS National ... (PERIODICAL ARTICLE) 4. IRS issues guidance regarding information document request contents. On June 3,1996, in response to an AICPA request, the IRS issued guidance to all Regional Chief Compliance Officers on the contents of the Service's ... (PERIODICAL ARTICLE) 5. Taxpayer Bill of Rights 2. On July 11, 1996, Congress approved by unanimous consent H.R. 2337, the Taxpayer Bill of Rights 2, a package of provisions aimed at helping taxpayers ... (PERIODICAL ARTICLE) 6. Update: the electronic federal tax payment system. Recent actions by Congress and the IRS have delayed the mandatory use of the IRS's new electronic funds transfer system known as EFTPS (electronic Federal ... (PERIODICAL ARTICLE) 7. Tax Division survey results on practitioner software uses. At the Spring 1996 AICPA Tax Division Meeting in Washington, D.C., the Tax Computer Applications Committee surveyed tax practitioners on their use of tax software. (PERIODICAL ARTICLE) 8. Entering foreign markets - one step at a time. Does a client have the urge to take his business overseas? A host of practical tax matters, such as using a foreign sales corporation, creating ... (PERIODICAL ARTICLE) 9. Practical planning for the decedent's final return. The preparation of a decedent's final Federal income tax return requires consideration of a number of issues, such as whether and when to file a ... (PERIODICAL ARTICLE) 10. Current developments - eligibility, elections and terminations; operations;... This update on S corporation develop meets reviews and analyzes the past year's rulings and decisions. But the major development is the liberalization of the ... (PERIODICAL ARTICLE)
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