Tag: 6112

Monetized Installment Sales – Proposed Regulations will Lead to Burdensome Reporting Requirements and Increased Scrutiny

Monetized Installment Sales, as previously written upon by Gray Edmondson,[1] have been subject to increased scrutiny by the IRS in recent years, making its “Dirty Dozen” list in each of the last three years.[2] The IRS remains on the offensive in scrutinizing such transactions, issuing proposed regulation under Internal Revenue Code Section 6011 in August…
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Goodbye Notice 2017-10

In a recent full Tax Court opinion[1], the Tax Court set aside Notice 2017-10, holding IRC § 6662A penalties are not to be imposed upon the taxpayer.[2] The Court’s reasoning was that the IRS failed to properly follow the notice-and-comment procedure, required under the Administrative Procedure Act. On December 23, 2016, the IRS issued Notice…
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[**Practice Alert: Corporate Transparency Act is Here: What You Need to Know**](https://esapllc.com/practice-alert-cta-mar-2024/)
[**Practice Alert: Corporate Transparency Act is Here: What You Need to Know**](https://esapllc.com/practice-alert-cta-mar-2024/)