NBAA 2011 Tactics to Avoid and Survive an IRS Audit

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What to do During the Audit • Claim grouping if circumstances permit (new rules after Jan 25, 2010) • Prepare analysis of active and passive income and expenses and request auditor allow restating • Test to see if insubstantial use criteria exists • 80/20 test Candelaria vs. United States 60101 • Less than 2% aircraft FMV or other comparisons Treas. Reg. § 1.469-4(d) 11003 • Regulations give taxpayer substantial latitude to establish material participation • Stress facts and circumstances
PAL/IRC§ 469 Cases • Leroy Candelaria and Elena Candelaria, Plaintiffs vs. United States of America, Defendant U.S. District Court, West. Dist of Texas, El Paso Division, Civil Action No. EP-06-CV-0216-KC • Eugene J. and Kathryn A. Schumacher vs. Commissioner Docket 60102 No. 18776-02S. 7/23/2003 • Thomas Kenvill, Plaintiff v. U.S.A: U.S. District Court, Dist. N.D., Northwestern Div., Civ. A3-96-135 11/06/97. 60103 60101
Page 1 and 2: NBAA 2011 Tactics to Avoid and Surv
Page 3 and 4: Resource Materials • Copies of to
Page 5 and 6: Audit Defense - Necessary Elements
Page 7 and 8: Passive Loss Limitations (PAL) IRC
Page 9 and 10: PAL Rules, Exceptions, and Grouping
Page 11: What to do Before the Audit • Sep
Page 15 and 16: Ordinary and Necessary Business Exp
Page 17 and 18: Ordinary and Necessary Business Exp
Page 19 and 20: What to do Before the Audit • Ana
Page 21 and 22: Aircraft Audit Issues Depreciation
Page 23 and 24: Sec. 280F Listed Property Rules •
Page 25 and 26: Depreciation Rates for Aircraft - M
Page 27 and 28: Bonus Depreciation Issues • Typic
Page 29 and 30: Single-Purpose Companies Have High
Page 31 and 32: What to do During the Audit • Dep
Page 33 and 34: Hobby Loss Rules - IRC §183 • Re
Page 35 and 36: Single Purpose Companies - Audit Ta
Page 37 and 38: Hobby Loss Rules (Continued) • Ta
Page 39 and 40: What to do During the Audit • Rev
Page 41 and 42: Aircraft Audit Issues Personal Use
Page 43 and 44: Personal Use of Company Aircraft
Page 45 and 46: Personal Use Of Company Aircraft -
Page 47 and 48: What to do During the Audit • Exp
Page 49 and 50: Flight Department Company Issue - I
Page 51 and 52: Flight Department Company - How to
Page 53 and 54: What to do Before the Audit • Con
Page 55 and 56: Flight Department Company - Cases P
Page 57 and 58: Every Issue Won at Field Audit Leve
Page 59 and 60: Supervisor Negotiations • Negotia
Page 61 and 62: 90-Day Letter • If taxpayer does
Page 63 and 64:
The Appeals Process • Appeal leve
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Advantages in Appealing • Appeals
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The Appeals Hearing • Informal co
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Fast Track Mediation • Small Busi
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COURT OPTIONS
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U.S. Tax Court • Once a case is d
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Final Points • Be sure to incorpo
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Flight Tax Systems, Inc. - Coming S
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NBAA 2011 Tactics to Avoid and Survive an IRS Audit

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