Keith A. Wood

Federal Income Tax Update

I. No Reasonable Cause Penalty Defense where CPA did not Give Specific Advice about Erroneous Items; Johnson v. Commissioner, TC Memo 2023-116 Mr. and Mrs.…

Federal Income Tax Update: Part 4

I. Termination of S Corporation Status was Inadvertent where Shares were Owned by an IRA. In PLR 202319003, the IRS again demonstrated its willingness to…

IRS Attacks Tax-Deferred Attorney Fee Structures

Sometimes publicity is a bad thing, and notoriety is even worse. That seems to be the case with respect to an apparent major change in the IRS’s views on…

Federal Income Tax Update: Part 3

Recent Cases Involving the Mailbox Rule, Time Limits for Filing Tax Court Petitions, and Equitable Tolling for Late Filed Petitions Over the last few months,…

Federal Income Tax Update: Part 2

I. Audit Statistics: What Are Your Chances of Being Audited? The 2022 Internal Revenue Service Data Book contains audit statistics for years 2012 through…

Federal Income Tax Update

I. Shareholders of Bankrupt S Corporation Failed to Abandon Their Stock; Yaguda v. Commissioner, TC Summary Opinion 2022-21. Mr. and Mrs. Yaguda owned stock…

Federal Income Tax Update

This is the last of three installments of this article. I. Bookkeeper Falls Victim to Section 6672 Trust Fund Recovery Penalty; Kazmi, TC Memo 2022-13. In…

Federal Income Tax Update

This is the second of three installments of this article.  I. Contemporaneous Written Acknowledgment Rules for Charitable Contributions of Aircraft and…

Federal Income Tax Update

This is the first of three installments of this article.  I. Audit Statistics: What Are Your Chances of Being Audited? The 2021 Internal Revenue Service Data…

Federal Income Tax Update: Part II

I. IRS Continues to Crack Down on S Corporation Disguised Wages. In Ward & Ward Company v. Commissioner, T.C. Memo. 2021-32, the Tax Court held payments…