Thought-provokinganalysis and opinion on federal tax issues

Category Archives: Procedural Tax Matters

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/

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Legislative History Versus Regulation Preambles

September 21, 2020

by Monte A. Jackel

The attached is a short write up I have done relating to conflicting or potentially conflicting legislative history and regulation preambles. https://jackeltaxlaw.com/wp-content/uploads/2020/09/Of-Legislative-History-and-Regulation-Preambles.docx. I thought this would be of interest.

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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 […]

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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/.

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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/

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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/.

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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/

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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/

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