DANRVAN

Sounds to me like it will be used as part of their personal residence. Did they use their residence as collateral?

I can sure see a situation where it would be allowed. But for OP, I have to question what knowledge was derived from a "free" seminar with $x,xxx of related travel expenses. And if the knowledge was so critical to his/her profession, was there no other way to obtain it?

Excellent question. What is their intent? Hold as investment or use as part of their personal residence property? Sec 163(h) refers to sect 121 for definition of personal residence. Section 1.121-1(b)(3)(i) outlines conditions where an adjacent lot is considered part of personal residence.

Was it really necessary for him to attend the seminar and incur all of the travel expense?

Judy, your post and experience are greatly appreciated on this board. I agree with you that if OP involves E&P he needs to dig much further, sorry my last reply was not clearer.

I agree with Abby Normal, AAA is moot. OP did not mention E&P, that is a whole different animal.

To be honest, you need to ask yourself if you are qualified for this engagement. If the stock is stepped to FMV at DOD, the gain passed through should be offset by a capital loss upon liquidation, due to the difference between inside and outside basis. It is critical that the distribution and dissolution occur in the same year.

Your client is not paying all the actual cost that are factored in the the standard mileage rate. In that case the standard rate does not accurately reflect his cost.

They are asking you to elect the interim closing of the books method. It will match income and expenses to the time period of ownership. Therefore it is more equitably unless income and expenses are even throughout the year. Unlike S-Corps, partnerships must use the interim closing method unless an election is made to use the proration method,

So do I! I have had clients with exchanges of out of state property for Oregon property, but not vice versa. Oregon wants to make sure that somewhere down the road the source of income is not forgotten! Oregon also has a a form 18-WC that can require escrow agents to withhold Oregon tax when property is sold to non-residence at a gain.

Sounds to me like your client had Oregon Source Income per ORS 316.127 (2)(a) and needs to file Oregon Form 40-N.

The Debit Brothers The Audit Family Print-N JAM HHH and the Exemptions

That depends on if they are held for market or breeding. Raised livestock do not have any basis whether held for breeding or market. LIvestock purchased for breeding are depreciated. Livestock purchased for resale are inventory. Sales of raised breeding stock go on part one of 4797 and are capital gains. Sale of purchased breeding stock go on part three of 4797 and subject to depr recap. Those two statements lead to the possibility of a hobby versus business. Proceed with caution!

And the 65 day rule which gives him or her several more weeks to make a deemed distribution for 2024?

The estate is an eligible shareholder. There was no internal change, just a change in stock ownership. That is not a reason to file a 2553.

Not sure why you are filing form 2553 in that situation. Shares passed from decedent to estate to wife.

I have used the payroll module of EasyACCT EasyACCT Business Write-Up System desktop for years with no complaints. The last last price after discount was $982, but also includes depreciation, loan amortization, along with write-ups and general ledger which I personally uses for my business's. There is no extra charges for multiple clients, just the yearly flat fee and unlimited support which I rarely use. It also allows direct deposit to employees.

You can't unconditionally take losses for three years in a row.

I don't believe that is correct statement. Under section 183(d) there is a "presumption" that the activity is for profit if gross income exceeds expenses for three out of five years. Meeting the 3 out of 5 year rule is not a slam dunk. Presumption is the key word. For example you cannot shuffle income and expense around to show a meager profit.

LLC is a disregarded entity and subject to Hobby Loss rules.

You need documentation that legal ownership was transferred to the charity.

I would not file it in that situation for a number of reasons.

I was sceptical, but case laws says that is correct; a transfer of an appreciated asset is not an assignment of income. HAROLD N. SHELDON, 62 TC 96, 04/25/1974 "An operating farmer who donates crops to a charity before he recognizes income from them is not required to include the value of the crops in his income.2 The farmer has merely assigned to the charity a property asset which has appreciated in value. Neither the harvesting nor the donative transfer of the product of his capital and services is a taxable event. See Campbell v. Prothro, 209 F.2d 331 (C.A. 5, 1954); Stuart A. Rogers, 38 T.C. 785 (1962); and White v. Brodrick, 104 F.Supp. 213 (D.Kan. 1952), appeal dismissed per curiam 198 F.2d 751 (C.A. 10, 1952); cf. Tatum v. Commissioner, 400 F.2d 242, 246-247 (C.A. 5, 1968), affirming"

File it when received and request an abatement of penalty if needed.

I see a potential issue with assignment of income. It will probably depend on the facts and circumstances.