This Podcast is about temporary regulations that deal with start-up and corporate and partnership organization costs. Interestingly enough, the new regulations now create an automatic election to expense/amortize all such costs, and treat problems related to the identification of costs or the proper year to begin amortization as accounting method issues.

The materials are located online at http://www.edzollars.com/2008-07-14_Section_195.pdf .

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This PodCast is about the impact of life insurance premiums and death benefits on an S corporation's accumulated adjustments account. It will focus on the more general issues of the relevance (and lack of relevance) of AAA for an S corporation and its shareholders, and how the item is computed.

The materials are available at http://www.edzollars.com/2008-07-07_AAA.pdf .

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This Podcast pertains to HSA Accounts. The IRS has issued guidance in the form of a series of questions and answers related to Health Savings Account in Notice 2008-59. This podcast covers some of the planning and design opportunities available under this Notice.

Written materials for this podcast can be downloaded from http://www.edzollars.com/2008-06-30_HSA_Guidance.pdf .

Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast is part two of a series on the proposed regulations for preparer penalties. .

The materials are at http://edzollars.com/2008-06-23_Penalty.pdf .

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This PodCast is the first of what will be a series of two on the proposed regulations for preparer penalties. Considering the length of the regulations and podcast, the first hour is in this file to listen to and digest, with part two to be posted later.

The materials are at http://edzollars.com/2008-06-23_Penalty.pdf .

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This PodCast reviews the step transaction doctrine and where the line is drawn when we deal with the application of the step transaction doctrine in the formation of a family limited partnership. The IRS attempted to use their victory in the Senda case to get the same result in Holman v. Commissioner, 130 TC No. 12. But in an opinion that reminds us of the importance of the facts of the specific case in question, the Tax Court refused to take that step.

Materials for this week's podcast can be downloaded from http://edzollars.com/2008_06_09_Holman.pdf. Be sure to also look at the commentary of Owen Fiore, Paul Hood, and Jeff Pennell in our LISI Estate Planning archives.

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This PodCast concerns a Court of Claims case that deals with an IRS examination and the imposition of the fraud penalty--a penalty the Court of Claims found was not justified. The case is the one of Gagliardi v. United States, 2008 TNT 98-20, and is instructive both in the outline of the law, as well as allowing us to consider the ways an examination like this could spin out of control and result in a taxpayer being assessed the fraud penalty in a case like this.

The materials can be downloaded from http://www.edzollars.com/2008-06-02_FraudandtheDentist.pdf.

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Simplified employee pensions (SEPs) are a popular retirement plan for extremely small businesses, with one of the key attractions being that don't require many of the formalities of regular qualified plans. But that has led to taxpayers treating them too informally, and in this case(Brown v. Commissioner, TC Summary 2008-56) a taxpayer discovered the hard way what can be the consequences of failing to faithfully follow the simplified rules for this type of plan.

The materials for this podcast can be found at http://www.edzollars.com/2008-05-26_SEP_Issue.pdf .

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This PodCast deals with a Fifth Circuit ruling in Kornman & Associates, Inc. v. United States on whether a taxpayer who set up a Son of BOSS style shelter would get the benefit that was expected--and the taxpayer was disappointed. The case offers a chance to review the unusual impact that liabilities have in a partnership context, as well as the question of just what is a liability for this purpose.

The materials for this podcast can be downloaded at http://www.edzollars.com/2008-05-19_Partnership_Liabilities.pdf .

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This PodCast deals with the problems that might be encountered by a taxpayer who tries to hand file a return. In the case of Allnut, Sr. v. Commissioner, 2008-1 USTC 50,310 the taxpayer failed to make delivery as required by the regulations, and the court found that what the taxpayer had to live with the date a document could finally be documented as being in the District Director's office--which was less than year years before the date the IRS issued an assessment.

Materials for this week are available at http://www.edzollars.com/2008-05-09_Hand_Carried.pdf.

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