May. 15.

Partners weren’t limited partners ..Self-employment tax exclusion explained by the Tax Court.

Partners weren’t limited partners for purposes of self-employment tax exclusion Castigliola, TC Memo 2017-62TC Memo 2017-62 The Tax Court has held that, while neither the Code nor any regulatory authority define “limited partner” for purposes of the Code Sec. 1402(a)(13) rule that excludes certain partnership income earned by limited partners from the self-employment tax base, under the ordinary meaning of the term “limited partner”, the taxpayers—attorneys who were members of a professional limited liability company (PLLC)—were not limited partners under Code Sec. 1402(a)(13). The Court also held that unidentified moneys in the PLLC’s attorney trust account were not partnership taxable
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Apr. 14.

Court of Appeals for the Ninth Circuit Agrees with Shea Holmes, which affirmed the Tax Court decision earlier this year – Great win !

IRS disagrees with the Court of Appeals for the Ninth Circuit  on when a.. “developer recognizes income under a completed contract method. AOD 2017-03,04/13/2017 IRS has announced its nonacquiescence with the holding of the Court of Appeals for the Ninth Circuit in Shea Holmes, which affirmed the Tax Court, that concluded that taxpayers who developed large, planned residential communities had used a permissible accounting method that clearly reflected their income. The taxpayers maintained that completion and acceptance under the completed contract method of accounting under Code Sec. 460 did not occur until the common improvements and amenities were completed. Background. Under
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