Thought-provokinganalysis and opinion on federal tax issues

Category Archives: Ethics and Tax Practice

A Principal Purpose Regs Over The Past Few Decades

October 26, 2020

by Monte A. Jackel

I am attaching a short write-up on the “a principal purpose” anti-abuse regulations generally. I thought this would be of interest. https://jackeltaxlaw.com/wp-content/uploads/2020/10/A-Principal-Purpose.docx.

Read More

Procedurally Taxing Blog Post By Me On Guaranteed Payments and the Validity of Tax Regulations

October 9, 2020

by Monte A. Jackel

This blog post from the Procedurally Taxing blog site discusses the guaranteed payment as interest issue in the context of how to challenge the validity of tax regulations. I thought it would be of interest. https://procedurallytaxing.com/consistency-and-the-validity-of-regulations/

Read More

Disguised Sales and the Centralized Partnership Audit Regime

June 3, 2020

by Monte A. Jackel

I posted this recently in the Procedurally Taxing blog. https://procedurallytaxing.com/disguised-sales-to-partnerships-bba-centralized-audits-and-due-process/. It deals with disguised sales to partnerships, the BBA centralized partnership audit regime, whether the selling partner’s gain is part of the imputed underpayment, and the due process issue raised if the selling partner is separately audited on the sales gain which is not treated […]

Read More

Recent Presidential Executive Order and Its Potential Effects on Tax Regulations

May 21, 2020

by Monte A. Jackel

I recently posted this on the Procedurally Taxing blog. It deals with the potential effects of a recent presidential executive order on tax regulations. I thought it would be of interest. https://procedurallytaxing.com/executive-order-on-regulatory-relief-to-support-economic-recovery/.

Read More

Procedurally Taxing Blog Post On the APA and Tax Regulations

May 15, 2020

by Monte A. Jackel

Thought this would be of interest. https://procedurallytaxing.com/conservation-easement-donation-and-the-validity-of-tax-regulations/

Read More

Procedurally Taxing Blog by Me On The Role of FAQs

May 8, 2020

by Monte A. Jackel

Just published this on the Procedurally Taxing blog on the role of FAQs. Thought it would be of interest. https://procedurallytaxing.com/the-proper-role-of-faqs/. See also https://procedurallytaxing.com/.

Read More

Another Procedurally Taxing Blog Post by me on amended tax returns

May 5, 2020

by Monte A. Jackel

This post on the Procedurally Taxing blog deals with whether amended tax returns can be mandated by the IRS. I thought this would be of interest. https://procedurallytaxing.com/the-newest-time-machine/

Read More

Procedurally Taxing Blog Item By Me

May 4, 2020

by Monte A. Jackel

This blog is a tax procedure blog by Professors Book, Fogg et al. https://procedurallytaxing.com/helpful-links/. I thought the item I posted on tax returns and the coronavirus pandemic would be of interest. https://procedurallytaxing.com/the-wavering-due-date-for-tax-returns/

Read More

Passthroughs and Special Industries Must Spin Off Partnerships As A Separate Division

December 27, 2019

by Monte A. Jackel

I recently read a news story in the tax press about recommended changes to the IRS as part of the mandated report due next October under the Taxpayer First Act, P.L. 116-25. The act mandates a report to Congress relating to potential reorganization changes to the IRS. Although this act is directed at the Internal […]

Read More

My Revised CV

November 1, 2019

by Monte A. Jackel

Read More

Partnership FAQs Inappropriate

October 31, 2019

by Monte A. Jackel

Read More

Cryptocurrency Guidance Defective

October 16, 2019

by Monte A. Jackel

Read More