This week we look at:

• Special agent in charge of Los Angeles CID talks about their potential use of the virtual currency question on Schedule 1, Form 1040.

• Taxpayer wins on claim LLC was not a sham, but finds the result is actually worse when court rules amounts paid to law firm were start-up expenses under §195 TAM rules that taxpayer did not have an intangible related to synergistic benefits that could be written off.

• Taxpayer could not use claim of right provision under §1341(a) to claim a deduction related to gain recognized in prior year when trustee of grantor sold stock that trustee was barred from selling by the trust agreement.

• IRS and taxpayer agree that a regulation on the books since 2001 mandates a result different from what the court had arrived at when agreeing with IRS position on §7502(a) and late filed returns asserted originally in the case.

An audio only version of this week’s broadcast can be streamed or downloaded below:

Articles for this week’s update can be downloaded below:

2020-02-03 Current Federal Tax Developments