Federal Tax Podcast for the Week of June 1, 2010

1. Credits on Volkswagen Vehicles Will Phase Out Beginning July 1, 2010
Citation: Notice 2010-42, 5/25/10

2. Taxpayer Who Failed to Exclude Portion of Pension From Tax in Years Now Closed to Amendment Could Not Use Alternative Methods to Recover Lost Basis in Open Years
Citation: PLR 201021042, 5/28/10

3. IRS, After Having Settled in Favor of Taxpayer Three Times Before, Prevails in Tax Court Challenging That Payments Were Not Nontaxable Disability
Citation: Lukovsky V. Commissioner, TC Memo 2010-117, 5/27/10

4. No Deduction Allowed For Payments to Purported 419 Plan Far in Excess of Annual Benefit Promised Under the Plan
Citation: Curcio, Et Al V. Commissioner, TC Memo 2010-115, 5/27/10

5. HSA Limits to Remain Unchanged for 2011
Citation: Revenue Procedure 2010-22, 5/24/10

6. Estate That Discovered Assets After Filing Estate Tax Return Allowed to Make Late §2056 QIP Election
Citation: PLR 201020002, 5/21/10

7. Gift Tax Paid Within Three Years of Death of Nonresident Who is Not a U.S. Citizen Not Treated as Part of U.S. Taxable Estate
Citation: CCM 201020009, 5/21/10

8. Penalties for Late Filing of Estate Tax Return Refunded Where IRS Failed to Consider Good and Sufficient Cause for Late Extension Request
Citation: Estate Of Proske V. United States, US District Court for the District of New Jersey, No. 2:09-00670, 5/25/10

9. Fees Received Prior to Effective Dates of §§6111 and 6707 Will Count if Advice Was Given After Effective Date
Citation: CCA 201021021, 5/28/10

10. IRS Clarifies Extent of Judicial Review in §6707a Reportable Transactions
Citation: Chief Counsel Email 201020020, 5/21/10

11. Taxpayer Who Admitted He and Preparer Had "Agreed to Cover Each Other's Backs" Properly Convicted of Filing False Returns and Conspiracy
Citation: United States V. Kruse, Ca7, No. 09-4077, 5/25/10

12. Supreme Court Declines to Review Holding That Tax Accrual Workpapers Not Protected By Work Product Privilege
Citation: United States V. Textron, Supreme Court Denial of Certiori, Ca1, No. 07-2631, 5/24/10

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