Category Archives: Ethics and Tax Practice
Is A New Treasury and IRS Transition On The Way?
November 8, 2020
by Monte A. Jackel
Presidential transitions bring extreme changes within the Treasury Office of Tax Policy and the IRS Office of Chief Counsel, usually starting the day after the election results are in and continuing through the date of inauguration of a new president. I saw this play out once in 1992-1993 when serving on the staff of the […]
Read MoreA 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://secureservercdn.net/198.71.233.96/wk8.36e.myftpupload.com/wp-content/uploads/2020/10/A-Principal-Purpose.docx.
Read MoreProcedurally 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 MoreDisguised 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 MoreRecent 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 MoreProcedurally 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 MoreProcedurally 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 MoreAnother 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 MoreProcedurally 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 MorePassthroughs 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 MoreMy Revised CV
November 1, 2019
by Monte A. Jackel
Read MorePartnership FAQs Inappropriate
October 31, 2019
by Monte A. Jackel
Read MoreCryptocurrency Guidance Defective
October 16, 2019
by Monte A. Jackel
Read More