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Ever wonder what the IRS looks for when auditing tax returns of law firms and their owners? The IRS has developed Audit Technique Guides (ATGs) to assist their agents during audits by providing insight into issues and accounting methods unique to specific industries. ATGs explain industry-specific examination techniques and include common, as well as unique, industry issues, business practices, and terminology. Guidance is also provided on the examination of income, expenses, interview techniques, and evaluation of evidence. And yes, the IRS has developed an ATG for the legal industry.
A Guide for the Legal Industry
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The Article 8 opt-in election adds an additional layer of complexity to the already labyrinthine rules governing perfection of security interests under the UCC. A lender that is unaware of the nuances created by the opt in (may find its security interest vulnerable to being primed by another party that has taken steps to perfect in a superior manner under the circumstances.
There's current litigation in the ongoing Beach Boys litigation saga. A lawsuit filed in 2019 against Nevada residents Mike Love and his wife Jacquelyne in the U.S. District Court for the District of Nevada that alleges inaccurate payment by the Loves under the retainer agreement and seeks $84.5 million in damages.
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The real property transfer tax does not apply to all leases, and understanding the tax rules of the applicable jurisdiction can allow parties to plan ahead to avoid unnecessary tax liability.