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/
Read MoreLegislative 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.
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/
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