A notice of deficiency issued by the IRS to a U.S. citizen who claimed to be a bona fide resident of the U.S. Virgin Islands for the tax years at issue was valid; therefore, the court had jurisdiction. The notice of deficiency had been issued after it was determined that the individual did not qualify…
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About: Ronald Marini
Recent Posts by Ronald Marini
Chief Counsel to Follow ‘Bluebook' Citation in Tax Court
The IRS Office of Chief Counsel March 13 issued a notice (CC-2012-007) stating that The Bluebook: A Uniform System of Citation is the source for citation to be used in legal work, including U.S. Tax Court documents. Note that case citations should be to the official reporter that is listed in T1 of the Bluebook,…
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Taxmasters files for Bankruptcy Protection
Taxmasters files for bankruptcy protection. Maybe now they can actually settle for Pennies on the Dollar? Read more at: Tax Times blog
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Bearer Notes – Non Deductible, Ordinary Income Rates and Not Qualify as Portfolio Debt.
Notice 2012-20 provides guidance relating to the portfolio interest exception, the short term debt exception under section 1.6049-5(b)(10), and the excise tax under section 4701 in connection with the repeal of section 163(f)(2)(B)(the bearer debt repeal). Notice 2012-20 will be published in the Internal Revenue Bulletin 2012-13, dated March 26, 2012. Issuers of debt obligations that…
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