Western CPE Podcast Network

Western CPE Podcast Network

By Western CPEBusinessCareers
Download on the App Store

Western CPE Podcast Network episodes

  • Tony #038; Damien#8217;s Top 10: How to Fail the SPA Test
    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.
    13 min
  • Tony #038; Damien#8217;s Top 10: Mom Doesn#8217;t Fly for Free
    A retired airline pilot took advantage of a “fly for free” fringe benefit, providing relatives with free airline tickets. Those relatives didn’t include the value of those tickets in income on their 2016 tax returns, and the IRS issued a notice of deficiency. The ensuing disagreement hinged on one question: Who is an “employee” under the meaning of Section 132(h)? 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.
    13 min
  • Tony & Damien's Top 10: Damien's Favorite Tax Case of 2022

    In Rogerson v. Commissioner, an aerospace entrepreneur grappled with the IRS about the status of passive activity losses generated from his two yachts. Tony and Damien analyze why the Tax Court sided with the IRS in its assertions regarding the "five of ten-year rule." 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.

    34 min
  • Tony #038; Damien#8217;s Top 10: Damien#8217;s Favorite Tax Case of 2022
    In Rogerson v. Commissioner, an aerospace entrepreneur grappled with the IRS about the status of passive activity losses generated from his two yachts. Tony and Damien analyze why the Tax Court sided with the IRS in its assertions regarding the "five of ten-year rule." 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.
    34 min
  • Tony & Damien's Top 10: Tony's Favorite Tax Case of 2022

    Hoops LP v. Commissioner involves the former owner of the NBA's Memphis Grizzlies, who attempted to claim over $10 million in tax deductions for accrued but unpaid deferred compensation to two NBA players. Tony and Damien discuss what this means for business sellers and tax professionals. 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.

    25 min
  • Top 10 Tax Cases of 2022 with Tony Nitti and Damien Martin

    Tax cases and guidance can provide a key to unlocking a deep understanding of the tax law for tax professionals and also help them better serve clients in planning and structuring transactions. Join Tony Nitti and Damien Martin for their fourth annual conversational exploration of key lessons from Tony’s top ten cases of the 2022.

    This episode is a self-study video available from Western CPE that can be purchased for CPE credit. Visit https://wcpe.co/episode/321820 to get started.

    Here’s an overview of what they cover:

    1. Rogerson v. Commissioner (T.C. Memo 2022-49): Tax Court sided with IRS in asserting the taxpayer materially participated in an activity under the “five of ten-year rule.”
    2. TAM 202229036: Taxpayers must count years qualified for material participation under the Significant Participation Test in applying the “five of ten-year” test for purposes of the material participation tests under Temp. Reg. Sec. 1.469-5T.
    3. IRS Chief Counsel Advice Memorandum 202151005: Providing “extra” amenities and services to tenants could subject rental income to self-employment taxes.
    4. Hoops LP v. Commissioner (T.C. Memo 2022-9): Tax Court sustained the IRS’s disallowance of a deduction for accrued but unpaid deferred compensation obligations by an accrual-method taxpayer who sold a basketball team.
    5. Milkovich v. U.S. 24 F.4th 1 (9th Circ. 2022): The 9th Circuit permitted an IRC Sec. 163 deduction related to foreclosure proceeds.
    6. Musselwhite (T.C. Memo 2022-57): Tax Court determined that a taxpayer’s losses on the sale of four land lots he received from his LLC were capital losses.
    7. Starer v. Commissioner (T.C. Memo 2022-124): Tax Court determined a married couple who were controlling shareholders of an S corporation operating agriculture and horse-breeding businesses did not properly report transfers of property made by the corporation.
    8. Wendy J. Mihalik v. Commissioner (T.C. Memo 2022-36): Tax Court held a retired airline pilot had to include the value of standby tickets used by relatives that were neither his spouse nor dependent children in income.
    9. CCA 202204007: IRS concluded a business facilitating property rentals between lessors and lessees is providing brokerage services within the meaning of IRC Sec. 1202(e)(3)(A).
    10. Proc. 2022-19: Guidance on six areas where taxpayers otherwise would need to seek a Private Letter Ruling.

      11. Timestamps

      00:00:00 – Introduction

      00:08:36 – Rogerson v. Commissioner (TC Memo 2022-49)

      00:41:43 – TAM 202229036

      00:53:54 – IRS Chief Counsel Advice Memorandum 202151005

      01:09:26 – Hoops LP v. Commissioner TC Memo 2022-9

      01:33:28 – Milkovich v. U.S. 24 F.4th 1 (9th Circ. 2022)

      01:55:48 – Musselwhite (TC Memo 2022-57)

      02:20:58 – Starer v. Commissioner (TC Memo 2022-124)

      02:29:44 – Wendy J. Mihalik v. Commissioner (TC Memo 2022-36)

      02:42:04 – CCA 202204007

      02:53:34 – Rev. Proc. 2022-19

      03:15:17 – Closing Remarks

      3 hr 21 min
    11. Tony #038; Damien#8217;s Top 10: Tony#8217;s Favorite Tax Case of 2022
      Hoops LP v. Commissioner involves the former owner of the NBA's Memphis Grizzlies, who attempted to claim over $10 million in tax deductions for accrued but unpaid deferred compensation to two NBA players. Tony and Damien discuss what this means for business sellers and tax professionals. 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.
      25 min
    12. Top 10 Tax Cases of 2022 with Tony Nitti and Damien Martin
      Tax cases and guidance can provide a key to unlocking a deep understanding of the tax law for  tax professionals and also help them better serve clients in planning and structuring transactions. Join Tony Nitti and Damien Martin for their fourth annual conversational exploration of key lessons from Tony’s top ten cases of the 2022.
      These case studies are available as a Self-Study Video Course from Western CPE that can be purchased for CPE credit. Visit https://wcpe.co/episode/321820 to get started.
      Here’s an overview of what they cover:
      Rogerson v. Commissioner (T.C. Memo 2022-49): Tax Court sided with IRS in asserting the taxpayer materially participated in an activity under the “five of ten-year rule.”
      TAM 202229036: Taxpayers must count years qualified for material participation under the Significant Participation Test in applying the “five of ten-year” test for purposes of the material participation tests under Temp. Reg. Sec. 1.469-5T.
      IRS Chief Counsel Advice Memorandum 202151005: Providing “extra” amenities and services to tenants could subject rental income to self-employment taxes.
      Hoops LP v. Commissioner (T.C. Memo 2022-9): Tax Court sustained the IRS’s disallowance of a deduction for accrued but unpaid deferred compensation obligations by an accrual-method taxpayer who sold a basketball team.
      Milkovich v. U.S. 24 F.4th 1 (9th Circ. 2022): The 9th Circuit permitted an IRC Sec. 163 deduction related to foreclosure proceeds.
      Musselwhite (T.C. Memo 2022-57): Tax Court determined that a taxpayer’s losses on the sale of four land lots he received from his LLC were capital losses.
      Starer v. Commissioner (T.C. Memo 2022-124): Tax Court determined a married couple who were controlling shareholders of an S corporation operating agriculture and horse-breeding businesses did not properly report transfers of property made by the corporation.
      Wendy J. Mihalik v. Commissioner (T.C. Memo 2022-36): Tax Court held a retired airline pilot had to include the value of standby tickets used by relatives that were neither his spouse nor dependent children in income.
      CCA 202204007: IRS concluded a business facilitating property rentals between lessors and lessees is providing brokerage services within the meaning of IRC Sec. 1202(e)(3)(A).
      Proc. 2022-19: Guidance on six areas where taxpayers otherwise would need to seek a Private Letter Ruling.
      Timestamps
      00:00:00 – Introduction
      00:08:36 – Rogerson v. Commissioner (TC Memo 2022-49)
      00:41:43 – TAM 202229036
      00:53:54 – IRS Chief Counsel Advice Memorandum 202151005
      01:09:26 – Hoops LP v. Commissioner TC Memo 2022-9
      01:33:28 – Milkovich v. U.S. 24 F.4th 1 (9th Circ. 2022)
      01:55:48 – Musselwhite (TC Memo 2022-57)
      02:20:58 – Starer v. Commissioner (TC Memo 2022-124)
      02:29:44 – Wendy J. Mihalik v. Commissioner (TC Memo 2022-36)
      02:42:04 – CCA 202204007
      02:53:34 – Rev. Proc. 2022-19
      03:15:17 – Closing Remarks
      3 hr 21 min
    13. Welcome to the Wild West[ern] Podcast

      Who are we? Well, we’re The Western CPE Podcast Network. As a leader and innovator in the CPE industry, we enjoy finding new ways to bring you the tax, accounting, and finance content you need and want. So, we’re kicking off our podcast launch with a very special collaboration! Get ready for the Top 10 Tax Cases of 2022 with Damien Martin & Tony Nitti!

      1 min
    14. Welcome to the Wild West[ern] Podcast
      Who are we? Well, we’re The Western CPE Podcast Network. As a leader and innovator in the CPE industry, we enjoy finding new ways to bring you the tax, accounting, and finance content you need and want. So, we’re kicking off our podcast launch with a very special collaboration! Get ready for the Top 10 Tax Cases of 2022 with Damien Martin & Tony Nitti!
      1 min

    About Western CPE Podcast Network

    From the publisher's feed

    Welcome to the new Western CPE Podcast Network! We’re taking over your airways this year to grace your ears with the latest and greatest tax content. We’re bringing you the tax, accounting, and…