Tax Section
Publicly Traded Partnerships
Section 7704 provides a partnership is a publicly traded partnership if interests in the partnership are (1) traded on an established securities market or (2)…
What is a QSub?
As discussed in my February 2025 blog post Eligible S Corporation Shareholders, corporations generally cannot own the stock of S corporations, even if the…
Federal Income Tax Update
I. Wife Not Entitled to Any of Foreclosure Sales Proceeds of Husband’s Marital Home to Pay Husband’s Taxes Since Title was Solely in the Husband’s Name;…
Sale of Social Club Assets Upon Liquidation
Since 1916, Congress has exempted from income tax clubs formed to facilitate social interaction among their members. As a result, country clubs, hunting and…
Expanded Benefits for Qualified Small Business Stock Under the OBBB
The gain exclusion benefits for the sale of qualified small business stock (“QSBS”) have grown in popularity in recent years, in part due to the 2017 Tax…
Federal Income Tax Update
I. 2024 IRS Audit Statistics. The 2024 IRS Data Book released in April 2025 contains audit statistics for years 2014 through 2022, as of the fiscal year ended…
Classification of LLCs Under the Check-the-Box Regulations
Limited Liability Companies (or LLCs) were invented in Wyoming in 1977. They have since spread to all states and become one of the most popular entities to…
Disallowance of Deductions or Credits Under Section 269
Section 269(a) applies where a “person or persons acquire, directly or indirectly, control of a corporation” and “the principal purpose for which such…
Federal Income Tax Update
I. Real Property Distributed from Testamentary Trust Meets the Section 1031 “Held for Investment” Requirement; PLR 202449007. A testamentary trust…
Federal Income Tax Update
I. IRS Cannot Impose Tax on Withdrawals from an IRA It Seized; Hubbard v. Commissioner, 135 AFTR 2d 2025-484 (6th Cir). Mr. Hubbard was a Kentucky pharmacist.…