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Are Some Political Donors Going to Be Hit with a Hefty Gift Tax Liability?

by Dan Smith | May 16, 2011 | Entrepreneurs' Business Blog

There was quite a stir in the media this past week surrounding so-called “social welfare” organizations that are exempt from federal income tax under Section 501(c)(4) of the Internal Revenue Code. Unlike the better-known 501(c)(3) organizations, which are...

Employee vs. Independent Contractor: An Ongoing Conumdrum

by Dan Smith | May 13, 2011 | Entrepreneurs' Business Blog

Mr. Robinson taught classes at Temple University that were part of its Criminal Justice Training Program. Temple said that Mr. Robinson was an employee. Mr. Robinson disagreed and treated himself as an independent contractor on his income tax return. In effect, there...

Distributions to Roth IRA as Shareholder of Related Corporation Not Treated as Excess Contributions by U.S. Tax Court

by Dan Smith | May 12, 2011 | Entrepreneurs' Business Blog

The U.S. Tax Court decided an interesting case involving a Roth IRA last week. In effect, the Court’s decision meant that the IRS couldn’t have its cake and eat it, too. In Ohsman v. Commissioner of Internal Revenue, the taxpayer had established two...

Letter of Credit-Backed Low Floaters Still Afloat

by Dan Smith | May 9, 2011 | Entrepreneurs' Business Blog

Variable-rate demand municipal bonds backed by bank letters of credit are sometimes called “low floaters.” Although low floaters have been common in municipal bond circles for a long time, the credit crisis that hit in late 2008 resulted in an even larger...

United States Tax Court Continues to Provide Additional Hope for “Late Filed” Innocent Spouse Relief

by Dan Smith | May 6, 2011 | Entrepreneurs' Business Blog

In an opinion of the United States Tax Court filed yesterday, May 5, 2011, the United States Tax Court continued to hold that relief for innocent spouses  under Section 6015(f) of the Internal Revenue Code is not subject to the 2-year deadline that the Internal...

Welcome to DPS Legal Counsel’s Blog on U.S. Tax Law and Policy

by Dan Smith | May 5, 2011 | Entrepreneurs' Business Blog

Welcome to T for Taxes, T for Tennessee! It is my hope that you will find this blog to be a place where you will find interesting and provocative analysis and commentary on U.S. tax law and policy, as well as a discussion of significant recent developments in...
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