NBAA 2011 Tactics to Avoid and Survive an IRS Audit

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Hobby Loss Rules Treas. Reg. §1.183-2(b) 10502 IRS regulations provide a list of nine factors to test if an activity is for profit, such as 1. Manner in which taxpayer carries on the activity 2. Expertise of the taxpayer or advisors 3. Time and effort expended 4. Expectation of future profits 5. Expectation that assets will appreciate in value IRS also permits grouping of “hobby” activity with other profitable activity Treas. Reg. § 1.469-4(d) and Candeleria vs. Unites States 11003 60101
Hobby Loss Rules (Continued) • Taxpayer might aggregate “hobby” activity with profitable activity, 1.183-1(d) 10501 Owner Operating Company Dry Lease Aircraft Company NOTE: Include grouping decision reference in each tax return
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 and 12: What to do Before the Audit • Sep
Page 13 and 14: PAL/IRC§ 469 Cases • Leroy Cande
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: Single Purpose Companies - Audit 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
Page 65 and 66: Advantages in Appealing • Appeals
Page 67 and 68: The Appeals Hearing • Informal co
Page 69 and 70: Fast Track Mediation • Small Busi
Page 71 and 72: COURT OPTIONS
Page 73 and 74: U.S. Tax Court • Once a case is d
Page 75 and 76: Final Points • Be sure to incorpo
Page 77 and 78: Flight Tax Systems, Inc. - Coming S

NBAA 2011 Tactics to Avoid and Survive an IRS Audit

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