Revenue Procedure 2011-46 provides a book safe harbor method of accounting for taxpayers using the nonaccrual-experience (NAE) method of accounting under § 448(d)(5) of the Internal Revenue Code and § 1.448-2 of the Income Tax Regulations. In general, under the NAE book safe harbor method, taxpayers within the scope of the revenue procedure may compute its uncollectable amount by multiplying the portion of the year-end allowance for doubtful accounts on the taxpayer’s applicable financial statement that is

The Internal Revenue Service launched a new program that will enable many employers to resolve past worker classification issues and achieve certainty under the tax law at a low cost by voluntarily reclassifying their workers. This new program will allow employers the opportunity to get into compliance by making a minimal payment covering past payroll tax obligations rather than waiting for an IRS audit.

Preamble to Prop Reg 09/22/2011, Prop Reg § 300.0, Prop Reg § 300.12, Prop Reg § 300.13, Prop Reg § 300.14 IRS has issued proposed regs that would establish a $27 fee for taking the registered tax return preparer examination and a $33 fingerprinting fee in order to participate in the preparer tax identification number (PTIN), acceptance agent, and authorized e-file provider programs (collectively, the programs). These regs will be effective upon publication of a Treasury

Notice 2011-80 provides guidance to individuals who have or will obtain a preparer tax identification number (PTIN), including a provisional PTIN, or who become registered tax return preparers. 

The IRS has issued a draft version of 2011 Form 940, Employer’s Annual Federal Unemployment (FUTA) Tax Return. The draft version of the form takes into account the elimination of the 0.2% federal unemployment tax (FUTA) surtax, effective beginning with wages paid on July 1, 2011.

The Court of Federal Claims in Jenkins v. US, (Ct Fed Cl 09/15/2011) 108 AFTR 2d ¶2011-5277 has held that the majority owner, CEO, and principal financier of a publishing corporation was responsible for its nonpayment of payroll tax, and willfully failed to pay over the funds to the government. Although he didn’t exercise day-to-day control over the entity, he clearly had the capacity to do so. He also drew on company funds in an attempt

Notice 2011-72 provides that, when an employer provides an employee with a cell phone primarily for noncompensatory business reasons, the IRS will treat the employee’s use of the cell phone for reasons related to the employer’s trade or business as a working condition fringe benefit, the value of which is excludable from the employee’s income and, solely for purposes of determining whether the working condition fringe benefit provision in section 132(d) applies, the substantiation requirements that the

In Larry E. Howard v. U.S., (CA 9 8/29/2011) 108 AFTR 2d ¶ 2011-5226, the Court of Appeals for the Ninth Circuit has affirmed a district court’s conclusion that the amount received by a dentist on the sale of his wholly owned dental-practice professional service corporation that was allocated to his personal goodwill was in fact a corporate asset. As a result, the amount was recharacterized as a dividend to him from his corporation. Beliveau Law