NBAA 2011 Tactics to Avoid and Survive an IRS Audit

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What to do Before the Audit • Personal Use of Company Aircraft: • Amend employee personal tax returns to include SIFL • Amend company returns to recognize the entertainment cost disallowance rules for aircraft-owning entity • Amend returns for non-business use deduction for individually-owned and flown aircraft • Document business flights; make sure flight logs support business and non-business use IRC § 274(d)(4) 10305
What to do During the Audit • Expect the auditor to disallow all costs, expenses and depreciation until taxpayer proves business use • If SIFL overlooked, request auditor permit amending the 1040 returns • If entertainment cost disallowance deductions were overlooked, request auditor permit amending company returns • Key strategy is to get business use of the aircraft deducted (think about the future aircraft use)
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 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: Personal Use Of Company Aircraft -
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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