Western CPE Podcast Network

Tony #038; Damien#8217;s Top 10: How to Fail the SPA Test


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The "Significant Participation Activities Test" and "Five of Ten Years Test" are used to determine if a taxpayer materially participates in an activity. The question considered in TAM 202229036 is this: Does participation via the SPA rule count for purposes of the "Five of Ten Years" test? The results might surprise you. In this episode, Tony and Damien break down the IRS's analysis, as well as what it means for taxpayers. This case study is part of a Self-Study Video Course available from Western CPE that can be purchased for CPE credit. Visit https://wcpe.co/podcast to get started.
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Western CPE Podcast NetworkBy Western CPE

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