A quarterly magazine from the National Association of Enrolled Agents
Fall 2024 vol.42 no.3

Feature Articles

Fall 2024
Navigating Tax Relief: Understanding Injured Spouse vs. Innocent Spouse Relief
Feature Article

Navigating Tax Relief: Understanding Injured Spouse vs. Innocent Spouse Relief

Tax professionals often encounter complex situations where marital obligations intersect with tax liabilities, especially when dealing with joint returns. In such cases, both spouses assume ... Desmond Hudson, EA

Fall 2024, Feature Article, Form 8857, innocent spouse relief, tax relief, injured spouse relief, Form 8379
To Acquiesce or Not: The IRS’s Actions on Decisions
Feature Article

To Acquiesce or Not: The IRS’s Actions on Decisions

Despite their importance in tax administration, there has been very little written about the Internal Revenue Service’s (IRS) Action on Decisions (AODs) processes, as well as its inclination to focus on certain Internal Revenue Code (IRC) sections. An understanding of... Joel M. DiCicco, CPA, Philippe Dubois, and Richard S. Gendler, JD

Fall 2024, Feature Article, Tait v. Western Maryland Railway Co., Summary Opinions, IRM 36.3.1.2 (2), IRM 36.3.1.2 (4), Tax Court, Action on Decisions, AOD, Nonacquiescence, Acquiescence, Commissioner v. Sunnen
Will Your Client’s LLC Operating Agreement Make an Election Under Subchapter S Invalid?
Feature Article

Will Your Client’s LLC Operating Agreement Make an Election Under Subchapter S Invalid?

Organization of a business enterprise as a limited liability company (LLC) has a number of advantages. In addition to ease of formation, state LLC acts dispense with many of the formalities required for corporations and wide latitude is given to... Patrick D. Dimmitt

Fall 2024, Feature Article, Private Letter Ruling 202110010, Corporate Governing Provision Statement, Form 8832, §704, §3.06(d), §1362(f), §83(b), s corporation, Treas. Reg. §1.704-1(b)(2), stock, Treas. Reg. §1.704-1(b)(2)(ii)(b)(2), employee, §1361(1)(D), Private Letter Ruling 202111011, election, Treasury Regulation §1.1361-1(l)(1), Private Letter Ruling 202310001, LLC, §338(h)(10), Uniform Limited Liability Company Act, Form 1120-S, Subchapter S, ULLCA, safe harbor, Private Letter Ruling 201949009, §105(b), debt, Private Letter Ruling 201930023, Rev. Proc. 2022-19, limited liability company, Private Letter Ruling 202315005, §3.06