October’s most interesting case involved a limited liability company that took losses in excess of basis flowing from a lower-tier partnership. IRS discovered the error after it was too late to correct the applicable returns. Does the LLC need to reduce basis in the lower tier partnership by those losses? The Tax Court said that it does. We also examine whether Collection Due Process appeal rights apply to FBAR penalties. The Tax Court noted that they do not. 

Learning Objectives: 

• List the latest regulations, rulings, and pronouncements from the IRS


• Summarize the most recent decisions out of the Tax Court and federal district courts around the country

NASBA Approved

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EA Approved

CPAacademy.org (Sponsor Id#: HURS9) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.

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