Fundamentals
Credits versus deductions, depreciation and basis, accounting-method changes, amended returns and statutes of limitations, audit readiness, and how to evaluate the advisors who sell specialty tax work.
Start here
7 piecesNo background assumed — the pieces that build the foundation.
Brief · Intro · 3 min
The IRS Independent Office of Appeals: protests, hazards, and when to use it
Appeals settles cases on the hazards of litigation — the government's own estimate of losing in court. What a protest must contain, how hazards settlement works, and when Appeals beats going straight to Tax Court.
Brief · Intro · 3 min
Anatomy of an IRS exam: from first letter to 30-day letter
How a business examination actually runs — information document requests, the notice of proposed adjustment, the 30-day letter — plus the rights you hold throughout and the practical dos and don'ts for specialty-tax claims.
Brief · Intro · 4 min
Circular 230, explained
Circular 230 is the Treasury regulation governing practice before the IRS: competence, diligence, standards for return positions, and fee rules. Its restriction on contingent fees for refund claims is why the specialty-tax fee model deserves scrutiny.
Brief · Intro · 4 min
First-time penalty abatement: the relief you qualify for by having behaved
First-time abatement (FTA) is an administrative waiver that removes failure-to-file, failure-to-pay, and failure-to-deposit penalties for a single period if the taxpayer has a clean compliance history for the prior three years. It requires no excuse, no story, and often no more than a phone call — but it does not cover accuracy penalties, and using it costs you its availability for the next three years.
Brief · Intro · 4 min
Form 4562, part by part: where depreciation actually gets reported
Form 4562 collects Section 179 elections (Part I), bonus depreciation (Part II), MACRS on current-year property (Part III), listed property (Part V), and amortization (Part VI). Cost segregation results land as reallocated basis across the MACRS classes — or, for look-back studies, as an 'other depreciation' catch-up rather than new Part III entries.
Brief · Intro · 3 min
What outranks what: the hierarchy of tax authority
Statute beats regulation, regulation beats revenue procedure, and a private letter ruling binds no one but its recipient. How the hierarchy works, and how 'substantial authority' weighs each rung.
Brief · Intro · 3 min
How to read the Internal Revenue Code
The Code is Title 26 of the United States Code, organized title → subtitle → chapter → section → subsection. Here is how the citation system works, where to read it free, and why secondary summaries mislead.
The working layer
18 piecesThe practitioner's day-to-day rules, mechanics, and traps.
Guide · Working · 6 min
The specialty-tax calendar: deadlines that cannot be fixed later
A quarter-by-quarter planning calendar for a business using the research credit, Section 174A expensing, cost segregation, and estimated taxes — organized around the elections that die if missed: the payroll offset, partial dispositions, and Form 3115 windows.
Guide · Working · 7 min
How to choose a specialty tax provider
A neutral framework for evaluating firms that sell R&D credit studies, cost segregation, and energy certifications: fee models, the questions that separate quality shops from credit mills, red flags, and what a defensible deliverable actually contains.
Guide · Working · 7 min
Depreciation basics: MACRS from first principles
How MACRS actually works — basis, recovery periods, the half-year, mid-quarter, and mid-month conventions, declining balance versus straight line, Section 179 versus bonus — and why depreciation is a deferral, not a subsidy.
Guide · Working · 7 min
Tax credits versus deductions: the arithmetic, the character, and the strategy
A credit reduces tax dollar-for-dollar; a deduction reduces taxable income, so its value depends on your marginal rate. Here is the full picture — including refundability, carryforwards, and when a deduction actually wins.
Brief · Working · 4 min
Tax Court or refund forum: choosing where to litigate a tax dispute
The deficiency path leads to Tax Court — no prepayment, specialist judges, appeal to your regional circuit. The refund path requires paying first and suing in district court or the Court of Federal Claims, buying a possible jury, different precedent, and a Federal Circuit appellate route. For credit cases, the precedent map often decides the forum.
Brief · Working · 3 min
Tax incentives in M&A due diligence
How R&D credits, cost segregation, and other specialty items surface in a deal: quality-of-earnings treatment, Section 382/383 limits on carryforwards, and successor exposure for aggressive studies.
Brief · Working · 3 min
Net operating losses now: no carryback, indefinite carryforward, and the 80% haircut
Post-2017 net operating losses generally cannot be carried back but carry forward indefinitely, and when used they can offset only 80% of taxable income. The mechanics matter for specialty tax because catch-up deductions create NOLs — and because the 80% limitation guarantees residual taxable income that nonrefundable credits can absorb.
Brief · Working · 3 min
Interest on tax overpayments: rates, start dates, and the tax on the interest
The government pays interest on overpayments under Section 6611 — at the federal short-term rate plus 3 points for most taxpayers, less for corporations — generally from the return's due date. Why amended-return refunds arrive with interest, and why that interest is itself taxable.
Brief · Working · 4 min
Section 163(j) in brief: the business interest limitation and who escapes it
Section 163(j) caps deductible business interest at business interest income plus 30% of adjusted taxable income, with disallowed amounts carried forward indefinitely. Small businesses under the gross-receipts threshold are exempt, and real estate businesses can elect out — at the price of ADS depreciation on their buildings.
Brief · Working · 3 min
Audit-ready documentation: what holds up and what does not
Contemporaneous records — time tracking, design documents, invoices — are what sustain specialty tax claims on exam. Reconstructed narratives written after the fact are what lose them.
Brief · Working · 4 min
Entity choice and tax credits: where a credit is actually worth the most
A C corporation uses credits against its own 21% tax; a passthrough sends credits to owners, where Section 41(g) and the general business credit rules can strand them against insufficient or mismatched liability. Credits alone rarely decide entity choice — but they reliably tilt it, and the tilt runs toward whoever has liability the credit can reach.
Brief · Working · 3 min
Estimated taxes when credits and catch-up deductions are in play
How anticipated research credits, bonus depreciation, and Section 481(a) catch-ups flow into quarterly estimates — plus the annualized income method and the safe harbors that make precision optional.
Brief · Working · 4 min
The automatic method-change landscape: the annual list, the DCNs that matter, and the eligibility traps
Most accounting method changes specialty-tax work relies on are automatic: pre-approved in the IRS's annually updated List of Automatic Changes, filed by attaching Form 3115 to the return with no user fee. Knowing the landscape means knowing the designated change numbers, the eligibility rules, and the five-year prior-change limitation.
Brief · Working · 4 min
Reasonable cause and good faith: when reliance on an adviser actually protects you
Section 6664(c) waives accuracy penalties for taxpayers who acted with reasonable cause and good faith. Reliance on a qualified adviser can qualify — under a three-part test that reliance on a credit mill's sales pitch does not survive.
Brief · Working · 3 min
Statutes of limitations: assessment, refunds, and why timing kills late claims
Section 6501 gives the IRS three years to assess; Section 6511 gives taxpayers three years from filing or two from payment to claim refunds — with lookback rules that can zero out an otherwise timely claim.
Brief · Working · 3 min
The Section 6662 accuracy-related penalty, and how specialty credits trigger it
Section 6662 adds 20% to any underpayment attributable to negligence or a substantial understatement. What each prong means, how disclosure and substantial authority defend against them, and why aggressive credit claims are a standing invitation.
Brief · Working · 3 min
Amended returns versus superseding returns
A superseding return replaces the original before the filing deadline; an amended return corrects it afterward. The difference controls elections, penalties, and how refund claims must be framed.
Brief · Working · 3 min
Form 3115 and accounting method changes, briefly
What counts as an accounting method change, how automatic consent differs from advance consent, how the Section 481(a) adjustment works, and why filing a Form 3115 buys audit protection.
Pro details
2 piecesSpecialist nuance: edge cases, interactions, and planning.
Guide · Pro · 6 min
The general business credit: how Section 38 limits what you can actually use
Section 38 stacks most business credits into one pool, Section 38(c) caps how much of that pool can offset tax each year, and Section 39 carries the excess back one year and forward twenty. Here is the machinery, with worked numbers.
Brief · Pro · 4 min
Fixing a partnership return after BBA: AARs, push-outs, and why amended returns are mostly gone
Under the centralized partnership audit regime, a BBA partnership generally cannot amend a filed return — it files an administrative adjustment request (AAR), and favorable adjustments reach partners in the year the AAR is filed, not the year being fixed. That timing shift is why claiming missed credits or 174 relief is structurally harder in partnerships.