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IRS Debts Tax Procedure

“One of its Principal Purposes” for an Installment Sale

What if you could transfer depreciable assets from one legal entity that you own to another legal entity that you own, not report the gain from the sale until some future year, and then step up the tax basis in the assets due to the sale and start taking increased depreciation deductions using the stepped […]

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Federal Income Tax Tax Tax Deductions

Seismic Surveyor Entitled to G&G Expense Deductions

In CGG Americas, Inc. v. Commissioner, 147 T.C. 2, the U.S. Tax Court concluded that a seismic surveyor is entitled to geological and geophysical (G&G) expenses deductions even though they merely gathered data for license to third parties and did not engage in exploration or development work. Facts & Procedural History The taxpayer was in […]

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Federal Income Tax Tax Tax Deductions

Insurance Agent Denied Depreciation Deduction For Airplane

In Brown v. Commissioner, T.C. Memo. 2013-275, the U.S. Tax Court denied an insurance salesman’s bonus depreciation deduction for his private jet as it was not placed in service in the tax year. The case highlights the highly factual nature of determining when an asset is deemed to have been placed in service for tax […]

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Federal Income Tax

IRS Concludes Open-Air Parking Garages are Buildings

In recent Chief Counsel Memo #20125201F, the IRS concludes that open-air parking garages are considered buildings rather than land improvements for tax purposes and that a taxpayer’s conclusion to the contrary warrants the assessment of a negligence penalty. Classification as a building or land improvement presents a timing issue. A building generally has a 39-year […]