by Greg Bryant | Mar 20, 2013 | Commercial Real Estate
Parking Structures Recently there has been much discussion regarding the IRS General Counsel Memorandum # 20125201F. The memorandum pertains to the recommended assessment of a §6662 penalty on a taxpayer who took the position that an open air parking structure was a...
by Greg Bryant | Nov 30, 2012 | Commercial Real Estate, Tax Planning
On Tuesday, November 20, 2012, the IRS issued Notice 2012-73 relating to the temporary regulations for the deduction and capitalization of expenses relating to the acquisition, renovation, or improvement of real estate. Notice 2012-73 informs us that the IRS will be...
by Greg Bryant | Mar 14, 2012 | Commercial Real Estate, Cost Segregation
While the title of this article probably invokes a response from the reader such as “well – that’s a no-brainer”, that is exactly what happened in the case of AmeriSouth XXXII, Ltd v. Commissioner of Internal Revenue. The recently released T.C. Memo 2012-67 has...
