Podcasts about revenue rulings

This podcast provides an overview of federal income taxation, beginning with the historical and constitutional basis, particularly the Sixteenth Amendment, which granted Congress the power to tax income without apportionment. The lecture then discusses the roles of the IRS and Treasury Department. The main sources of tax law are the Internal Revenue Code (IRC), Treasury Regulations, Revenue Rulings, Revenue Procedures, and Judicial Decisions. Beyond raising revenue, tax policy is shaped by considerations such as encouraging homeownership or environmental responsibility.Gross income, as defined in IRC Section 61, includes "all income from whatever source derived" unless specifically excluded. Common examples are wages, salaries, interest, dividends, business income, and capital gains. Illegal income, gambling winnings, and prizes are also included. The Supreme Court defines gross income as undeniable accessions to wealth, clearly realized, and over which the taxpayers have complete dominion.Exclusions from gross income include gifts, inheritances, life insurance proceeds, certain fringe benefits, and municipal bond interest. Cancellation of Debt (COD) income is usually included unless it occurs during bankruptcy or insolvency.Filing statuses include single, married filing jointly or separately, head of household, and qualifying widow(er), which affect tax brackets, standard deductions, and credit eligibility. The U.S. tax system is progressive, meaning the marginal tax rate increases as income rises.The tax system encourages or discourages behaviors through charitable deductions, mortgage interest deductions, and retirement savings incentives. Tax considerations are integral to estate planning and business transactions.A hypothetical scenario illustrates these principles with an individual who has wages, side gig income, dividends, an inheritance, and installs solar panels. The analysis involves determining filing status, calculating gross income while considering exclusions, and identifying potential tax credits.

This lecture begins by outlining the historical and constitutional roots of the federal income tax. Early in American history, the federal government used excise taxes and tariffs to raise revenue, and only in special circumstances, such as the Civil War, did it introduce temporary income taxes. The Sixteenth Amendment in 1913 dramatically shifted the legal landscape, giving Congress the authority to impose an income tax without the need for apportionment among the states. This development paved the way for modern federal income taxation, removing most constitutional barriers that had previously hindered direct taxation of individual incomes.Next, the lecture covers how the federal tax system is organized. The Internal Revenue Service (IRS) enforces tax laws and issues guidance, while the Treasury Department oversees both the IRS and broader financial policies. Various authorities define tax law: the Internal Revenue Code (IRC) enacted by Congress; Treasury Regulations that interpret and clarify the Code; official Revenue Rulings and procedures from the IRS; and judicial decisions at multiple levels, including the U.S. Tax Court, district courts, courts of appeal, and potentially the Supreme Court. Together, these sources form a complex legal framework that practitioners must navigate.Tax policy goals also factor into the system's structure. While the primary purpose of taxation is to fund government operations, Congress uses the tax code to shape economic and social behavior, encouraging homeownership via mortgage interest deductions or fostering charitable giving through donation write-offs. This means that the Code is more than just a revenue-raising tool; it's also a mechanism for incentivizing and discouraging certain activities.A significant portion of the lecture is devoted to gross income, a concept anchored by IRC Section 61. This broad definition—“all income from whatever source derived”—captures wages, business profits, interest, dividends, rents, and many other forms of economic gain. Even illegal proceeds and certain prizes count as gross income, reflecting the principle that if a taxpayer obtains a clear economic benefit, it is presumed taxable. Nevertheless, there are notable exclusions: gifts, inheritances, certain fringe benefits, and life insurance proceeds are among the items that Congress or the courts have decided should not be included in gross income. Sometimes, these exclusions further a policy objective, such as not penalizing individuals receiving gifts or not taxing life insurance benefits that mitigate financial burdens upon death.The lecture then introduces the importance of filing status: single, married filing jointly, married filing separately, head of household, and qualifying widow(er). Each status affects how taxpayers fall into brackets in the progressive tax system, where higher marginal rates apply to additional increments of income. The system aims to tax those with greater resources more heavily, though fairness and efficiency debates remain. Thus, individuals with the same gross income may pay different effective tax rates, influenced by both filing status and the presence of deductions or credits.Finally, the lecture underscores the policy rationales embedded in the tax code. Deductions for retirement contributions or energy-efficient home improvements reveal the government's intent to channel societal behaviors. Because these incentives directly affect how people earn, save, and invest, attorneys and other professionals must understand both the letter of the law and the broader purpose it serves.Overall, Lecture 1 underscores that modern federal income taxation rests on a constitutional foundation, shaped by the Sixteenth Amendment, enforced by a multi-tier system of statutes, regulations, and court rulings, and guided by deliberate policy goals. The core concept of “gross income”—and the many exceptions that reduce it—forms the building block for tax liability calculation

 Understanding Short-Term Rental Tax Loopholes: Key Court Cases and Revenue Rulings Natalie discusses various court cases and revenue rulings that provide crucial guidance on this topic, including cases from 1965 to 2023. She highlights differing tax treatments based on the nature of services provided, whether the property is subject to self-employment tax, and the importance of understanding context to accurately apply tax laws. Tune in for a comprehensive overview of significant rulings and their implications for short-term rental property owners.Link To Court Cases:   https://www.natalie.tax/blog/strcasesFB Group For Tax Professionals:https://www.facebook.com/groups/realestatefortaxpros FB Group For Real Estate Investors:https://www.facebook.com/groups/REIKnowledgeVault 00:00 Introduction to Real Estate Taxing00:28 Understanding the Short-Term Rental Loophole01:01 Court Cases and Legal Guidance01:55 Debunking Myths About Short-Term Rental Laws02:59 Case Study: 1965 US Court of Appeals07:34 Revenue Rulings and Their Impact13:06 Two-Step Approach to Analyzing Services15:26 Exploring Substantial Services in Real Estate15:52 Court Cases on Retirement Benefits and Real Estate16:28 The Holohan v. Heckler Case Analysis19:28 Comparing Substantial Services in Different Contexts22:11 The Woodworth Case: Partnership and Self-Employment Tax25:46 The Morehouse Case: Land Rental and Government Programs28:34 Recent Developments in Short-Term Rentals and Tax Implications30:39 Conclusion and Further Resources 

https://player.vimeo.com/video/326056731https://www.currentfederaltaxdevelopments.com/podcasts/2019/3/23/2019-03-25-more-underpayment-relief QBI and disallowed passive losses Minister’s housing allowance ruled to be acceptable under the U.S. Constitution Pilot had no profit motive for business related to vintage World War II aircraft IRS suspends two Revenue Rulings related to active trade or business issues under §355 Relief from underpayment of estimated tax penalty expanded by IRS   Click to listen to the audio . Alternatively, you may download the file to your computer by right clicking your mouse, choosing "Save Target As", then

This week we look at: QBI and disallowed passive losses Minister’s housing allowance ruled to be acceptable under the U.S. Constitution Pilot had no profit motive for business related to vintage World War II aircraft IRS suspends two Revenue Rulings related to active trade or business issues under §355 Relief from underpayment of estimated tax penalty expanded by IRS Copyright 2019 Kaplan, Inc.

Given that the IRS and courts had a short week, we look back this week at a ruling from a few weeks back, as well as a related ruling from a year ago, that deal with the accountable plan rules, and how the IRS interprets the options for implementing those rules.  We look at Revenue Rulings 2006-56 and 2005-52.The materials can be downloaded at http://edzollars.com/2006-11-25_Accountable_Plan_Per_Diem.pdf .The podcast is sponsored by Leimberg Information Services, on the web at http://www.leimbergservices.com .

This PodCast deals with rulings related to the accountable plan rules, and how the IRS interprets the options for implementing those rules. Specifically, we will focus on Revenue Rulings 2006-56 and 2005-52.The materials can be downloaded at http://edzollars.com/2006-11-25_Accountable_Plan_Per_Diem.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast deals with rulings related to the accountable plan rules, and how the IRS interprets the options for implementing those rules. Specifically, we will focus on Revenue Rulings 2006-56 and 2005-52.The materials can be downloaded at http://edzollars.com/2006-11-25_Accountable_Plan_Per_Diem.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast deals with rulings related to the accountable plan rules, and how the IRS interprets the options for implementing those rules. Specifically, we will focus on Revenue Rulings 2006-56 and 2005-52.The materials can be downloaded at http://edzollars.com/2006-11-25_Accountable_Plan_Per_Diem.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Another Circuit chimes in on the issue of the FICA taxation of payments made in exchange for tenure rights as part of an early retirement package offered to teachers.  In a combined appeal of two contradictory opinions of lower courts under their jurisdiction, the Sixth Circuit upheld the lower court's finding in favor of FICA taxation in Appolini and reversed the opposite lower court holding in Klender, both cases that involved early retirement payments to teachers subject to Michigan's tenure law.The Sixth Circuit, in a 2-1 split decision, specifically called into question the Eigth Circuit's holding in North Dakota State University where payments for professor's tenure rights were held not to be subject to FICA.  We look at why the majority believes the North Dakota holding was in error, as well the reasoning behind the dissenting opinion.  As well, we consider the IRS changes to Revenue Rulings in this area, as well as how the courts dealt with the prior rulings that were applicable to these cases.The materials can be downloaded at http://edzollars.com/2006-06-17_FICA.pdf.The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com.

This PodCast concerns FICA taxation of payments made in exchange for tenure rights as part of an early retirement package offered to teachers. Another Circuit chimes in on the issue. In a combined appeal of two contradictory opinions of lower courts under their jurisdiction, the Sixth Circuit upheld the lower court's finding in favor of FICA taxation in Appolini and reversed the opposite lower court holding in Klender, both cases that involved early retirement payments to teachers subject to Michigan's tenure law.The Sixth Circuit, in a 2-1 split decision, specifically called into question the Eigth Circuit's holding in North Dakota State University where payments for professor's tenure rights were held not to be subject to FICA. We look at why the majority believes the North Dakota holding was in error, as well the reasoning behind the dissenting opinion. As well, we consider the IRS changes to Revenue Rulings in this area, as well as how the courts dealt with the prior rulings that were applicable to these cases.The materials can be downloaded at http://edzollars.com/2006-06-17_FICA.pdf. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com