Filling the void: can the IRS restructuring bring purpose and meaning to the random world of tax litigation?

Article Abstract:

The most positive potential changes which may result from provisions in the IRS Restructuring and Reform Act of 1998 are those actually influencing the operation of the IRS including how it conducts tax litigation. The IRS tax litigation process has lacked institutional unity in policymaking and administration. Judicial deference to administrative regulations and interpretation of law adds to the policy disarray. Consistent attention to uniform policy and administration concerns would be welcome.

Management, Practice, Tax appeals, Administrative agencies, United States. Internal Revenue Service, Government reorganizations

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Reconstruction of income by the Internal Revenue Service

Article Abstract:

The IRS has special methods and procedures for reconstructing income in cases of underreporting of income and failure to meet the requirements of IRC section 6001. The IRS may become aware of underrreported income and the need for auditing due to factors such as unusual losses or unusually low income compared to an industry average. Methods of reconstruction include net worth, cash expenditures, bank deposits, or a combination of those methods.

Analysis, Laws, regulations and rules, Tax accounting, Accounting and auditing, Tax administration and procedure, Tax returns

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S corp valuations: no definitive guidance despite W.L. Gross

Article Abstract:

Valuation of S corporations in light of the Tax Court's 1999 memorandum ruling in W.L. Gross, Jr. is the subject of this article in which the author commends the judge on focusing on the tax-affect rather than on the form of valuation accounting procedure.

Valuation, S corporations

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