Deductions: Overview and Conceptual Aspects (Portfolio 503)

Tax Management Portfolio, Deductions: Overview and Conceptual Aspects, No. 503-3rd, analyzes in depth the nature, concept, scope, and application of deductions, including an historical summary of the development of the concept of deductions, an analysis of the underlying constitutional issues, and a discussion of imputed deductions.

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Tax Management Portfolio, Deductions: Overview and Conceptual Aspects, No. 503-3rd, analyzes in depth the nature, concept, scope, and application of deductions, including an historical summary of the development of the concept of deductions, an analysis of the underlying constitutional issues, and a discussion of imputed deductions. In addition, each particular deduction is described, other than trade or business and for-profit activity deductions which are discussed in 505 T.M., Trade or Business Expenses and For-Profit Activity Deductions. For deductions that are the subject of other Portfolios, the description provides an overview and an introduction to the terminology and substantive requirements of the statutory or other provision that applies. For the other deductions the provision is analyzed in depth.

The analysis of the deductions is organized categorically. The major categories discussed are deductions allowable in any event (interest, taxes, charitable contributions, casualty losses, bad debts, etc.), special deductions limited to individuals (medical, alimony, cooperative housing corporation tenant-shareholder items, moving expenses, contributions to retirement savings plans, and personal and dependency exemptions), special deductions limited to corporations (dividends received, dividends paid, financial institutions, insurance companies, etc.), deductions allowed to estates and trusts, and detailed discussion of assignment of deductions and nuclear decommissioning expense deductions.


James Edward Maule

James Edward Maule, B.S., University of Pennsylvania (1973); J.D., Villanova University (1976); LL.M. (Taxation), George Washington University (1979); lecturer, Villanova University Graduate Tax Program and Tax Forum CLE Programs; lecturer, Philadelphia Bar Association Tax Section; member, Advisory Board on U.S. Income, Tax Management Inc.; former attorney-advisor, United States Tax Court, Judge Herbert L. Chabot; former attorney-advisor, Chief Counsel to the Internal Revenue Service; former Editorial Advisory Board member and Columnist, Journal of Limited Liability Companies; former lecturer, ALI-ABA; former lecturer, Tax Management Inc. & Continuing Legal Education Satellite Network; former lecturer, Pennsylvania Bar Institute; former lecturer, Georgetown University Law Center Institute on State and Local Taxation; former lecturer, The Dickinson School of Law CLE Programs; member, American Bar Association, Section of Taxation, Committee on S Corporations (Consultant and former Chair, Subcommittee on Subchapter S and State Law; former Chair, Subcommittee on Comparison of Partnerships and S Corporations); member, American Bar Association, Section of Taxation, Committee on Teaching Taxation (Chair, Subcommittee on Manuscripts and Unpublished Teaching Materials; member, Subcommittee on Important Developments); member, American Bar Association, Section of Taxation, Tax Practice Management Committee; member, American Bar Association, Section of Taxation, Formation of Tax Policy Committee; member, American Bar Association, Section of Taxation, Committee on Tax Structure and Simplification; former Chair, American Bar Association, Section of Taxation, Phaseout Tax Elimination Project; former member, American Bar Association, Section of Taxation, Task Force on Pass-Through Entities; former member, American Bar Association, Section of Taxation, Task Force on Legislative Recommendation No. 86-1; former member, Philadelphia Bar Association Tax Section; author and owner, TaxJEM Inc., publisher of computer assisted legal instruction programs; owner, JEMBook Publishing company, publisher of law and genealogy books; author of numerous books, monographs, and book chapters; contributor to various tax periodicals.

Table of Contents

Detailed Analysis

I. Introduction

A. Overview

1. The Nature of Deductions

2. The Significance of Deductions

3. The Concept of Deductions

4. The Scope of Deductions

5. The Application of Deductions

6. The Assignment of Deductions

B. Historical Background

1. Introduction

2. Early Federal Income Tax Statutes

a. The First Civil War Income Tax Act

b. The Second Civil War Income Tax Act

c. The Third Civil War Income Tax Act

d. The Reconstruction Era Income Tax Act

e. The Income Tax of 1894

f. The Corporate Excise Tax of 1909

3. Passage of the Sixteenth Amendment

4. Post-Sixteenth Amendment Income Tax Acts

a. Revenue Act of 1913

b. Subsequent Statutory Development

(1) Pre-Codification

(2) Internal Revenue Code of 1939

(3) Internal Revenue Code of 1954

(4) Internal Revenue Code of 1986

II. The Concept and Scope of Deductions

A. The Significance of Deductions

1. Introduction

2. Tax Liability Computation

a. In General

b. Other Income Tax Liabilities

(1) Tax-Exempt Organizations

(2) Additional Corporate Income Taxes

(3) Special Entities

(4) Other Situations

c. Other Federal Taxes

d. Impact on State and Local Income Taxes

3. Administrative Matters

a. Return Filing Requirements

b. IRS Computation of Tax

4. Measurement of Other Computation Steps

a. Deductions Used in Computational Base

b. Deductions Used in Special Tax Liability Computations

c. Impact of Claiming Deductions on Basis

5. Use as an Eligibility Factor

a. Gross Income Inclusions and Exclusions

b. Deductions

c. Tax Credits

d. Tax Attributes and Definitions

e. Nontax Financial Benefits

f. Nontax Attributes and Definitions

B. Concept and Definition

1. Introduction

a. Definitional Aspects

b. Other Aspects

2. The Concept of Expenditure or Outlay

a. In General

b. Economic Wealth

(1) Anticipated But Unrealized Income

(2) Uncompensated Services

(3) Unrented Property

c. The Impact of Reimbursement

(1) Effect on Deduction

(a) In General

(b) Reimbursement Includible in Gross Income

(c) Reimbursement Not Includible in Gross Income

(2) Failure to Seek Reimbursement

(a) In General

(b) Business Purpose Exception

(3) Indeterminable Right to Reimbursement

d. Substantiation of Expenditure or Outlay

(1) In General

(2) Strict Substantiation Requirements

(3) Less Strict Substantiation Requirements

3. The Concept of Statutory Allowance

4. The Concept of Preferred and Itemized Deductions

a. In General

b. Deductions Allowable in Computing Adjusted Gross Income

(1) Trade or Business Deductions

(a) In General

(b) Deductions Attributable to Carrying on Trade or Business

(i) In General

(ii) Direct Attribution

(iii) Interest

(iv) Taxes

(v) Tax Litigation Expenses

(vi) Losses

(2) Reimbursed Employee Trade or Business Deductions

(a) In General

(b) Unreimbursed Employee Business Expenses

(c) Reimbursement or Other Expense Allowance Arrangement

(i) In General

(ii) Reporting Simplification

(A) In General

(B) Unsubstantiated and Unreturned Expenses

(iii) Business Connection Condition

(iv) Substantiation Condition

(v) Excess Nonretention Condition

(vi) Reasonable Period of Time

(d) Determination of Reimbursed Expenses

(3) Certain Performing Artist Deductions

(a) In General

(b) Qualified Performing Artist

(c) Married Individuals

(4) Certain Public Official Expenses

(5) Certain Expenses of Elementary and Secondary School Teachers

(6) Overnight Travel Expenses of Military Reservists

(7) Losses From Sales or Exchanges of Property

(8) Deductions Attributable to Rents and Royalties

(9) Life Tenant and Income Beneficiary Deductions

(10) Self-Employed Individuals' Retirement Plan Deductions

(11) Retirement Savings Deductions

(12) Premature Withdrawal Penalty Deductions

(13) Alimony

(14) Reforestation Expenditure Deductions

(15) Certain Supplemental Unemployment Compensation Benefit Repayment Deductions

(16) Remitted Jury Pay

(17) Clean Fuel Vehicle and Refueling Property Deduction

(18) Moving Expense Deduction

(19) Medical Savings Account Contributions Deduction

(20) Education Loan Interest Deduction

(21) Higher Education Expense Deduction

(22) Health Savings Account Deductions

(23) Certain Attorney Fee and Court Cost Deductions

(24) Alimony Recapture Deduction

(25) Certain Personal Casualty Losses

(26) Housing Cost While Living Abroad

(27) Deductions for Losses from Marketable Stock Subject to Mark to Market Rules

c. The Significance of Adjusted Gross Income

5. The Standard Deduction

a. In General

b. Exceptions

c. Amount of Standard Deduction

(1) In General

(2) Limitation for Certain Taxpayers

(3) Additional Standard Deduction

(a) In General

(b) Qualifying Through Age

(c) Qualifying Through Blindness

d. Election to Itemize

(1) In General

(2) Change of Election

6. Deductions for Alternative Minimum Tax Purposes

a. In General

b. Adjustments

c. Tax Preference Items

7. Deductions Not Taken into Account for Certain Purposes

a. Computational Purposes

b. Characterization and Classification Purposes

C. Constitutional Concerns

1. In General

2. Limitations on Congressional Power to Enact Deductions

a. In General

b. Classification of Taxpayers for Deduction Purposes

c. Charitable Contribution Deductions

3. Failure to Provide or Continue Specific Deductions

4. Imposition of Limitations or Restrictions on Deductions

a. In General

b. Requirement that Deductions Be Substantiated

c. Requirement that There Be a Reduction in Wealth

d. Imposition of Conditions Precedent to Deduction

e. Restrictions Related to Timing

D. The Problem of Imputed Deductions

1. In General

2. Services Performed and Goods Produced for One's Self

3. Owner Use of Property

4. Imputed Interest, Original Issue Discount, and Unstated Interest

a. Below-Market Loans

(1) In General

(2) Application

(3) Below-Market Loans

(4) Below-Market Loans to Which Rules Apply

(5) Computation of Forgone Interest

b. Original Issue Discount

(1) In General

(2) Application

(a) In General

(b) Exceptions

(3) Determination of Existence of OID

(a) In General

(b) SRP

(c) Issue Price

(i) In General

(ii) Publicly Traded Instruments

(iii) Private Nonproperty Instruments

(iv) Section 1274 Instruments

(A) In General

(B) IPA, ASI, and QDI

(C) Exclusions from General Rule

(D) Exception for Cash Method Debt Instruments

(E) Exception for Personal Use Property

(v) Other Instruments

(4) Computation of OID Gross Income Inclusion

c. Unstated Interest

(1) In General

(2) Application

(a) In General

(b) Exceptions

(3) Determination of Unstated Interest

E. The Scope of Deductions

1. In General

a. Selectivity of Deduction Provisions

b. Types of Deductions

c. Affected Taxpayers

2. Deduction Limitations and Restrictions

a. In General

b. Types of Limitations and Restrictions

(1) In General

(2) Computational Limitations

(3) Avoidance of Double Benefits

(4) Timing Matters

(5) Public Policy Restrictions

3. Nonrecognition Transactions

a. In General

b. Postponement Concept

c. Types

d. Specific Provisions

(1) Like-kind Exchanges

(2) Transfers Between Spouses or Incident to Divorce

(3) Certain Reacquisitions of Real Property

(4) Transfers to Controlled Corporations

(5) Transfers to Partnerships

(6) Corporation's Exchange of Its Stock

(7) Exchange of Corporate Stock

(8) Corporate Reorganizations

(9) Distribution of Stock by Corporation

(10) Distribution of Stock and Securities of a Controlled Corporation

(11) Liquidation of Subsidiary

(12) Distributions of Property by Partnerships

(13) Insurance Policy Exchanges

(14) Certain Exchanges of U.S. Obligations

4. The Impact of Timing Rules

a. In General

b. Method of Accounting

(1) In General

(2) Principal Methods

(3) Restrictions on Method

c. General Rule for Timing of Deductions

d. Generally Applicable Exceptions

(1) Amount at Risk Deductions

(2) Passive Activity Deductions

(3) Disqualifying Stock Dispositions

e. Specifically Applicable Exceptions

(1) Prepaid Farming Expenses

(2) Mining and Solid Waste Reclamation and Closing Costs

(3) Nuclear Decommissioning Expenses

(4) Designated Settlement Funds

(5) Frozen Deposit Interest Deduction Deferral

5. Foreign Persons and Entities and Activities Abroad

a. In General

b. Deductions of Nonresident Aliens

(1) In General

(2) Deductions Allocable to Effectively Connected Income

(3) Deductions for Capital Losses Allocable to U.S. Sources

c. Foreign Corporations

(1) In General

(2) Deductions Connected with Effectively Connected Income

(3) Income from Sources Within the United States

d. Income Tax Treaties

e. Residents of Possessions and Puerto Rico

f. United States Taxpayers' Activities Abroad

(1) Foreign Earned Income and Housing Cost

(2) Controlled Foreign Corporations

(3) Domestic International Sales Corporations

(4) Qualified Electing Funds

F. The Passing Through of Deductions

1. In General

2. Partnerships and S Corporations

a. Partners

b. S Corporation Shareholders

3. Deductions in Respect of a Decedent

4. Deductions from an Interest in an Estate or Trust

a. In General

b. Deductions of Grantor Trusts

(1) In General

(2) Conditions Under Which Grantor Trust Rules Apply

c. Unused Loss Carryovers and Excess Deductions on Termination

5. Estate of a Bankrupt

6. Activities of U.S. Persons Abroad

III. Deductions Allowable Without Regard to Trade, Business, or For-Profit Activity

A. Interest

1. In General

2. Requisite Indebtedness

3. Determination of Interest

a. In General

b. Original Issue Discount

(1) In General

(2) Exceptions

(3) Special Rules

c. Redeemable Ground Rents

d. Installment Purchases Lacking Separately Stated Interest

e. Amortizable Bond Premium

(1) In General

(2) Determination of Amortizable Bond Premium

(3) Bond

(4) Election

f. Interest on Timeshare and Residential Lot Installment Sales

g. Interest on Nondealer Installment Sales

4. Limitations

a. Personal Interest Limitation

(1) In General

(2) Personal Interest

(3) Qualified Residence Interest

(a) In General

(b) Acquisition Indebtedness

(c) Home Equity Indebtedness

(d) Qualified Residence

(e) Mortgage Insurance Premiums

(4) Qualified Education Loan Interest

(a) In General

(b) Qualified Education Loan

(c) Deduction Limitations

b. Investment Interest Limitation

(1) In General

(2) Investment Interest

(3) Net Investment Income

c. Interest Related to Tax-Exempt Income

d. Disqualified Interest Paid by Covered Corporation

(1) In General

(2) Covered Corporation

(3) Excess Interest Expense

(4) Disqualified Interest

e. Interest on Disqualified Corporate Debt Instruments

f. Interest Connected to Corporate Acquisitions

(1) In General

(2) Corporate Acquisition Indebtedness

(3) Special Rules

g. Interest on Obligations Not in Registered Form

h. Accrued Market Discount Limitation

i. Short Term Obligation Net Direct Interest Expense Limitation

j. Reduction if Mortgage Credit Allowable

k. Interest Paid in Connection with Insurance Contracts

l. Carrying Charges

m. Interest Paid to Related Parties

n. Interest on Underpayments Arising from Undisclosed Reportable Transactions

5. Allocation of Interest Among Expenditures

a. In General

b. Expenditure Categories

(1) In General

(2) Specific Categories

c. Allocation of Debt and Interest Expense

(1) In General

(2) Allocation Period

(3) Reallocation

B. Taxes

1. In General

2. Qualified Tax

a. In General

b. State, Local, and Foreign Real Property Taxes

c. State and Local Personal Property Taxes

(1) In General

(2) Ad Valorem

(3) In Respect of Personal Property

d. State, Local, and Foreign Income, War Profits, and Excess Profits Taxes

e. State and Local Sales Taxes

(1) In General

(2) General Sales Tax

(3) Special Rules

(4) Separately Stated Tax

(5) Sales Tax Tables

f. Qualified Self-Employment Taxes

g. Qualified Generation Skipping Tax

h. Trade or Business and For-Profit Activity Taxes

(1) In General

(2) Tax

(3) Items Not Taxes

i. State, Local, and Foreign

j. Qualified Motor Vehicle Taxes

3. Exceptions

a. General Tax Disallowances

b. Capitalization Limitation

C. Charitable Contributions

1. In General

2. Charitable Contribution

a. In General

b. Governmental Unit

c. Charitable Organization

d. Veterans Organization

e. Fraternal Association

f. Cemetery Company Category

3. Transactions Treated as Charitable Contributions

a. Unreimbursed Expenses

b. Educational Organization Athletic Tickets

c. Student Maintenance

(1) In General

(2) Qualified Period

(3) Limitations

d. Native Alaskan Subsistence Whaling Expenses

e. Qualified Reformations

4. Exceptions

a. Consideration

b. Services

c. Traveling Expenses

d. Contributions to Trusts

(1) Remainder Interests

(2) Income and Other Interests

e. Partial Interests in Property

(1) In General

(2) Exceptions

(3) Qualified Conservation Contribution

(a) In General

(b) Qualified Real Property Interest

(c) Qualified Organization

(d) Exclusively for Conservation Purposes

(i) Conservation Purposes

(ii) Exclusively

f. Fractional Gifts

g. Certain Private Foundations

h. Donor Advised Funds

i. Expenditures to Influence Legislation

j. Lobbying Expenditures

k. Charitable Split-Dollar Insurance, Annuity, and Endowment Contracts

l. Communist Controlled Organizations

m. Qualified Conservation Contributions

n. Clothing and Household Items

o. Verification and Record Keeping

(1) In General

(2) Monetary Gifts

(3) Contributions of $250 or More

(4) Contributions of Property Exceeding $500

(5) Contributions of Used Motor Vehicles, Boats, and Airplanes

(6) Qualified Whaling Expenses

5. Amount of Charitable Contribution

a. In General

b. Use of Automobile

c. The Gain Reduction Rules

(1) First Gain Reduction Rule

(2) Second Gain Reduction Rule

(3) Relaxation of Reduction

(4) Capital Asset

(5) Contributions of Less Than Entire Interest

(6) Contributions of Inventory and Business Property

(a) In General

(b) Qualified Contribution

(7) Contributions of Scientific Property

(a) In General

(b) Qualified Research Contribution

(8) Certain Contributions of Computer Technology and Equipment

(a) In General

(b) Qualified Computer Contribution

(9) Contributions of Qualified Appreciated Stock

(a) In General

(b) Qualified Appreciated Stock

(i) In General

(ii) Ten Percent Limitation

(10) Taxidermy Property

d. Interest Adjustments

6. Payment During Taxable Year

a. Accrual Method Corporations

b. Future Interests in Tangible Personal Property

7. Limitations

a. Corporations

(1) In General

(2) Carryforwards

b. Individuals

(1) Fifty Percent Limitation

(a) In General

(b) Carryforwards

(c) Fifty Percent Donees

(i) In General

(ii) Church

(iii) Educational Organization

(iv) Medical

(v) Educational Support

(vi) Governmental Unit

(vii) Public Charity

(viii) Private Foundation Test

(ix) Public Private Foundation Test

(2) Thirty Percent Limitation

(3) Contributions of Capital Gain Property

(a) Contributions Subject to 50% Limitation

(i) In General

(ii) Application and Avoidance

(iii) Capital Gain Property

(b) Contributions Not Subject to 50% Limitation

(i) In General

(ii) Carryforwards

(iii) Application

(4) Qualified Conservation Contributions

D. Casualty Losses

1. In General

2. Casualty

a. In General

b. Qualified Insolvent Financial Institution Losses

(1) In General

(2) Qualified Insolvent Financial Institution Loss

(3) Qualified Individual

(4) Qualified Financial Institution

(5) Election

(a) In General

(b) Alternative Election

3. Exceptions

a. Insurance Claim

b. Estates

c. Inventories

4. Computation of Casualty Loss

a. In General

b. Basis Limitation

c. Basis Override

d. Insurance and Other Reimbursement Reduction

5. Computation of Deduction

a. Floor Amount

b. Adjusted Gross Income Limitation

(1) In General

(2) Trusts and Estates

c. Suspension of Limitations for Hurricane Losses

6. Characterization Rules

E. Bad Debt Deduction

1. In General

2. Nonbusiness Debts of Individuals

3. Exceptions

4. Worthless Bad Debts

a. Bad Debts

b. Worthlessness

F. Prevention of Double Taxation

1. Estate Tax Paid on Items of Income in Respect of Decedent

a. In General

b. Computation of Deduction

(1) In General

(2) Estates and Trusts

2. Repayments of Previously Taxed Social Security Benefits

3. Unrecovered Investment in Annuities

a. In General

b. Annuitants

c. Beneficiaries

IV. Special Deductions Limited to Individuals

A. Medical Expenses

1. In General

2. Scope of Deduction

a. Taxpayers Entitled to Deduction

b. Persons Whose Medical Expenses Qualify

(1) In General

(2) Spouses

(3) Dependents

3. Limitations on Deduction

a. 7.5% Limitation

(1) In General

(2) Adjusted Gross Income Recomputations

b. Coordination With Credits

c. No Maximum Limitation

d. Reimbursements

(1) In General

(2) Dependent's Resources

(3) Corporations and Shareholders

(4) Awards to Crime and Disaster Victims

(5) Disability Benefit Payments

(6) Personal Injury Awards for Future Medical Expenses

(7) Personal Injury Awards for Past Medical Expenses

(8) Payments Received Under Employer Accident and Health Plans

(9) Payments Received Under Long-Term Care Insurance Contracts

4. Definition of Medical Care

a. In General

b. Medicine, Drugs, and Supplies

(1) Prescription Items

(2) Nonprescription Items

c. Special Diets

(1) In General

(2) Vitamins

(3) Allergy Diets and Organic Foods

(4) Salt-Free Diets

d. Insurance

(1) In General

(2) Medical Care Insurance

(3) Qualified Long-Term Care Insurance Contract

(4) Medical Care Coverage Under Combined Policies

(5) Medicare and Social Security Payments

(6) Private Death and Disability Policies

(7) State Disability Funds

e. Capital Expenditures

(1) In General

(2) Capital Expenditures Not Related to Permanent Improvement of Property

(a) In General

(b) Assistance for Seeing and Hearing

(c) Vehicles and Mobility Devices

(d) Equipment Affecting Health Environment

(e) Medical Equipment

(f) Other Equipment Used for Medical Purposes

(g) Other Activities

(h) Miscellaneous Items

(3) Capital Expenditures Related to Permanent Improvement of Property

(a) In General

(b) Home Elevators

(c) Swimming Pools and Hot Tubs

(d) Heating, Plumbing, and Central Air-Conditioning

(e) Attached Garage

(f) Lead Removal

(g) Accommodations to Principal Residence of Disabled Person

(h) Fallout Shelters

(i) Home Office

(4) Operation and Maintenance of Capital Assets

f. Funeral and Burial Expenses

g. Child Care Expenses

(1) Day Care Centers

(2) Baby Nurses

(3) Babysitting Needed to Aid Sick Person

h. Cosmetic Surgery

i. Transportation

(1) In General

(2) Automobile Expenses

(a) Auto Standard Rate

(b) Depreciation

(3) Distant Travel

(4) Lodging

(5) Companions

(6) Commuting Expenses

(7) Pre-Employment Expenses

(8) Loss on Sale of Home

j. Personal Attendant and Nursing Services

k. Specific Medical Services

(1) Nature of Provider

(2) Type of Care

(3) Other Situations

l. Education Expenses

(1) College Tuition

(2) Special Education

(3) Regular Education

m. In-Patient Care

(1) Hospitals

(2) Institutions Other Than Hospitals

(3) Life-Care Residences

5. Timing of Deduction

a. In General

b. Payments Made with Borrowed Money

c. Prepayment

(1) In General

(2) Exception

d. Reimbursements

(1) Reimbursements of Expenses Deducted in Previous Year

(2) Reimbursements Received in Year Expenses Are Paid

6. Substantiation

B. Alimony

1. In General

2. Identification Numbers

C. Cooperative Housing Corporation Tenant-Stockholder Payments

1. In General

2. Amount Deductible

a. In General

b. Cooperative Housing Corporation Real Estate Taxes

c. Cooperative Housing Corporation Interest

d. Depreciation

(1) In General

(2) Computation

(3) Basis Limitation

e. Proportionate Share

3. Cooperative Housing Corporation

a. In General

b. Stock Owned by Governmental Units

c. Prior Approval of Occupancy

4. Tenant-Stockholder

5. Exceptions

D. Moving Expenses

1. In General

2. Deductible Moving Expenses

3. Expenses of Individuals Other Than the Taxpayer

4. Conditions for Allowance

a. In General

b. Distance Condition

c. Employment Time Condition

(1) In General

(2) Exceptions

(3) Anticipated Satisfaction

5. Members of the Armed Forces

6. Moves to Foreign Countries

7. Certain Moves from Foreign Countries

a. In General

b. Qualified Retiree Moving Expenses

c. Qualified Survivor Moving Expenses

E. Contributions to Retirement Savings Plans

1. In General

2. Qualified Retirement Contributions

3. Limitation on Amount of Deduction

a. In General

(1) Individual Retirement Plan

(2) Section 501(c)(18) Plans

(3) Taxpayers Filing Joint Returns

(4) Married Individuals

b. Active Participants in Certain Pension Plans

(1) In General

(2) Active Participant

(a) In General

(b) Exceptions

(i) Certain Members of Armed Forces Reserves

(ii) Volunteer Firefighters

(3) Active Participant Reduction Amount

c. Exceptions

d. Carryforward of Excess Contributions

4. Exceptions

F. Archer MSA Payments

1. In General

2. Eligible Individual

a. In General

b. High Deductible Health Plan

c. Permitted Insurance

d. Small Employer

e. Numerical Limitation Exception

(1) In General

(2) Active MSA Participant

(3) MSA-Participating Employer

3. Medical Savings Accounts

a. In General

b. Qualified Medical Expenses

4. Limitations

a. Monthly Limitation

b. Compensation Limitation

c. Employer Contribution Limitation

d. Dependency Limitation

G. Qualified Tuition and Related Expenses

1. In General

2. Limitations

a. Dollar Limitations

b. Other Limitations

3. Qualified Tuition and Related Expenses

a. In General

b. Limitations

H. Health Savings Account Payments

1. In General

2. Limitations

3. Eligible Individual

4. High Deductible Health Plan

5. Permitted Insurance

6. Health Savings Account

a. In General

b. Qualified Medical Expenses

I. Personal and Dependency Exemptions

1. In General

2. Personal Exemptions

a. Taxpayer

(1) In General

(2) Exception

b. Spousal

(1) In General

(2) Gross Income

(3) Proof

(4) Joint Return

3. Dependency Exemptions

a. In General

b. Exceptions

(1) Dependents of Other Taxpayers

(2) Dependents Filing Joint Returns

(3) Citizenship

(a) In General

(b) Citizen

(c) Resident

(d) Constitutionality

c. Qualifying Child

(1) In General

(2) Qualifying Child Relationship

(3) Age Requirements

(4) Same Principal Place of Abode

(5) Two or More Taxpayers Claiming Qualifying Child

d. Qualifying Relative

(1) In General

(2) Qualifying Relative Relationship

(a) In General

(b) Dependents of Spouses

(c) Determination of Particular Relationships

(d) Household Test

(i) In General

(ii) Occupation and Maintenance

(iii) Exceptions

(A) Spouse

(B) Relationship Violating Local Law

(C) Employees

(3) Gross Income Condition

(a) In General

(i) Definition

(ii) Specific Types for Dependency Exemption Purposes

(iii) Sources

(iv) Cost of Goods Sold and Deductions

(b) Income of Handicapped Persons

(i) In General

(ii) Sheltered Workshop

(iii) Permanently and Totally Disabled

(c) Proof

e. Support Conditions

(1) In General

(2) Provided by Taxpayer

(a) Amount Taxpayer Obligated to Provide

(b) Amounts Provided by Others

(c) Amounts Not Support Provided by Taxpayer

(d) Timing

(e) Child Support Arrearages and Prepayments

(3) More Than One Half

(a) In General

(b) Support Provided by the Individual

(c) Support Provided to the Individual

(d) Multiple Support Agreements

(4) Support

(a) Items of Support in General

(b) Lodging

(c) Education

(d) Medical and Dental Care and Insurance

(e) Automobiles and Boats

(f) Items Not Included in Support

(i) In General

(ii) Visitations

(iii) Capital Expenditures

(iv) Medical Expense Reimbursements

(g) Measurement of Support Items

(h) Scholarships

(i) In General

(ii) Military Payments

(iii) Disabled Individuals

(5) Proof

(a) In General

(b) Specific Proofs

(c) Compliance with Burden of Proof

(d) Evidence

(6) Constitutionality

f. Child

(1) In General

(2) Legally Adopted Child

(3) Eligible Foster Child

(4) Acknowledged Child

(5) Deceased Children

(6) Unborn Children

g. Student

(1) In General

(2) Full-Time Attendance

(3) Full-Time On-Farm Training

(4) Qualified Educational Organization

h. Children of Divorced or Separated Parents

(1) In General

(2) Applicable Child

(3) Exemption Allowed to Custodial Parent

(4) Exemption Released by Custodial Parent

(5) Certain Pre-1985 Instruments

(a) In General

(b) Qualified Pre-1985 Instrument

4. Exemption Amount

a. In General

b. Phaseout

(1) In General

(2) Threshold Amount

(3) Applicable Percentage

(4) Reduction and Elimination of the Phaseout

5. Hurricane Katrina and Midwestern Displaced Person Exemption

V. Special Deductions Limited to Corporations

A. Specific Deductions Allowed to Corporations

1. Dividends Received Deductions

a. Dividends from Most Domestic Corporations

(1) In General

(2) Applicable Percentage

(3) Qualifying Dividends

(a) In General

(b) Affiliated Group

(c) Life Insurance Company Groups

(4) Twenty-Percent Dividends

(5) Scope of Dividends

(a) Mutual Savings Banks

(b) Regulated Investment Companies

(c) Real Estate Investment Trusts

(d) Public Utility Preferred Stock Dividends

(e) Foreign Corporations

(6) Debt-Financed Portfolio Stock Dividends

(a) In General

(b) Portfolio Stock

(c) Portfolio Indebtedness

(d) Base Period

(7) Average Indebtedness Percentage

b. Public Utility Preferred Stock Dividends

(1) In General

(2) Computation

(3) Exception for Qualifying Dividends

(4) Exception for Debt-Financed Portfolio Stock Dividends

c. Certain Foreign Corporation Dividends

(1) In General

(2) Applicable Percentage

(3) Qualified 10% Owned Foreign Corporation

(4) U.S.-Source Portion

(a) In General

(b) Post-1986 Undistributed Earnings

(c) Post-1986 Undistributed U.S. Earnings

(d) Excluded Earnings and Profits

(5) Eligible Foreign Corporation

(6) Eligible Dividends

(7) FSC Foreign Trade Income Dividends

(8) FSC Effectively Connected Income Dividends

2. Dividends Paid Deductions

a. The § 561 Dividends Paid Deduction

(1) In General

(2) Elements

(3) Dividends Paid During the Taxable Year

(a) In General

(b) Liquidating Distributions

(i) Not From Personal Holding Company

(ii) Personal Holding Company

(c) Real Estate Investment Trusts

(d) Affiliated Groups

(4) Dividends Deemed Paid During the Taxable Year

(a) Accumulated Earnings Tax

(b) Personal Holding Company Tax

(5) Consent Dividends

(a) In General

(b) Consent Stock

(c) Exceptions

(6) Dividend Carryover

b. The Personal Holding Company Deficiency Dividends Deduction

(1) In General

(2) Deficiency Dividend

(3) Determination

(4) Procedure

(5) Effect on § 561 Dividends Paid Deduction

c. Regulated Investment Company and Real Estate Investment Trust Deficiency Dividends Deduction

(1) In General

(2) Qualified Investment Entity

(3) Deficiency Dividend

(a) In General

(b) Limitations

(4) Determination

(5) Adjustment

(6) Procedure

(7) Effect on § 561 Dividends Paid Deduction

d. Public Utility Preferred Stock Dividends Paid Deduction

(1) In General

(2) Computation of Deduction

(3) Dividends Paid During the Taxable Year

(a) In General

(b) Multiple Business Activities

(4) Public Utility

(5) Preferred Stock

(a) In General

(b) Replacement Preferred Stock

3. Terminal Railroad Corporations

a. In General

b. Discharge of Liability Exclusion

c. Terminal Railroad Corporation

d. Related Terminal Income

e. Related Terminal Services

4. Amortization of Disallowed Mineral Deductions

5. Transfer of a Residual Interest in a REMIC

B. Specific Entities

1. Financial Institutions

a. Bad Debt Deduction on Securities

(1) In General

(2) Bank

(3) Security

b. Reserves for Losses on Bank Loans

(1) In General

(2) Bank

(3) Addition to Reserve for Bad Debts

(4) Restrictions on Large Banks

(a) In General

(b) Large Bank

c. Interest and Dividends Paid on Deposits by Membership Banks

(1) In General

(2) Depositor Interest and Dividends

(a) In General

(b) Serial Association and Bonus Plan Amounts

(3) Membership Banks

d. Savings Association Insurance Fund Fees

2. Life Insurance Companies

a. In General

b. General Deductions

(1) In General

(2) Death Benefits Deduction

(3) Reserve Increase Deduction

(a) In General

(b) Reserve Items

(c) Increase in Policy Cash Values With Respect to Policy or Contract

(4) Policyholder Dividends Deduction

(a) In General

(b) Policyholder Dividends

(c) Special Rules

(5) Dividends Received Deduction

(a) In General

(b) 100% Dividends

(c) Reduction

(6) Operations Loss Deduction

(a) In General

(b) Operations Loss Carryovers and Carrybacks

(c) Loss From Operations

(d) Offsets

(7) Assumption of Liability Consideration Deduction

(8) Reimbursable Dividends Deduction

(9) Modified Normal Deductions

c. Small Life Insurance Company Deduction

(1) In General

(2) Very Large Life Insurance Company Exception

(a) In General

(b) Assets

(3) Tentative Life Insurance Company Taxable Income

(a) In General

(b) Noninsurance Business Items

(4) Special Rules for Controlled Groups

(5) Foreign Life Insurance Company Limitation

(a) In General

(b) Required U.S. Assets

(i) In General

(ii) Total Insurance Liabilities

(iii) Domestic Asset/Liability Percentage

(c) Domestic Investment Yield

3. Other Insurance Companies

a. Other Insurance Company General Deductions

(1) In General

(2) Trade or Business Deduction

(3) Interest Deduction

(4) Taxes Deduction

(5) Other Insurance Company Loss Deduction

(a) In General

(b) Reduction

(i) In General

(ii) Prorated Amounts and 100% Dividends

(iii) Dividends Paid by Insurance Companies

(iv) Exception

(6) Other Insurance Company Capital Loss Deduction

(a) In General

(b) Applicable Sales and Exchanges

(c) Modification of Capital Loss Carryforward Rules

(7) Other Insurance Company Bad Debt Deduction

(8) Exempt Interest Deduction

(9) Depreciation and Depletion Deduction

(10) Charitable Contributions Deduction

(11) Other Insurance Company Itemized Deduction

(12) Deferred Compensation Deduction

(13) Dividend Deduction

(14) Dividends Received Deduction

(15) Mortgage Guaranty Insurance Deduction

(a) In General

(b) Computations

(c) Limitations

(d) Required Bond Purchase

b. Interinsurer Deductions

c. Health Insurance Organization Deduction

(1) In General

(2) Health Insurance Organizations

(a) In General

(b) Existing Blue Cross or Blue Shield Organization

(c) Deemed Blue Cross or Blue Shield Organization

(d) Other Health Insurance Organization

(3) Computation of Deduction

(a) In General

(b) Adjusted Surplus

(i) In General

(ii) First Taxable Year

(c) Adjusted Taxable Income and Net Operating Loss

(4) Limitation

4. All Insurance Companies

a. Excess Undiscounted Unpaid Losses Deduction

(1) In General

(2) Excess Undiscounted Unpaid Losses

(a) In General

(b) Discounted Unpaid Losses

(3) Special Estimated Tax Payment Rules

b. Insurance Policy Acquisition Expense Amortization

(1) In General

(2) Amortization Period

(a) In General

(b) Controlled Groups

(c) Exception

(3) Specified Policy Acquisition Expenses

(a) In General

(b) General Deductions

(c) Deduction Maximum

(d) Net Premiums

(i) In General

(ii) Accounting Rules

(iii) Reinsurance

(e) Specified Insurance Contracts

(f) Group Life Insurance Contract

(g) Negative Net Premiums

(i) In General

(ii) Treatment of Negative Capitalization Amount

5. Cooperatives

a. In General

b. Patronage

(1) In General

(2) Patronage Dividends

(3) Nonqualified Written Notice of Allocation Redemptions

(4) Payment Period

c. Marketing

(1) In General

(2) Per-Unit Retain Allocations

(3) Nonqualified Per-Unit Retain Certificate Redemptions

(4) Payment Period

d. Nonpatronage Distributions by Exempt Farmers' Cooperatives

VI. Deductions Allowed to Trusts and Estates

A. In General

B. Specific Trust and Estate Deductions

1. Personal Exemption

2. Charitable Contribution Deduction

a. In General

b. Amounts Paid for Charitable Purposes

(1) In General

(2) Charitable Purposes

(3) Subsequent Year Payments

c. Amounts Permanently Set Aside for Charitable Purposes

(1) In General

(2) Qualified Trusts

(3) Charitable Purposes

d. Pooled Income Funds

(1) In General

(2) Charitable Purpose

(3) Pooled Income Fund

(4) Computation

3. Net Operating Loss Deduction

4. Depreciation and Depletion Deductions

5. Pollution Control Facility Amortization Deduction

6. Backup Withholding Credit Deduction

7. Distributions Deduction

a. Simple Trusts

(1) In General

(2) Simple Trust

(3) Limitation

b. Estates and Complex Trusts

(1) In General

(2) Complex Trust

(3) Limitations

(4) Property Distributions

(5) Exceptions

(a) Gifts and Bequests

(b) Charitable Distributions

(6) Subsequent Taxable Year Distributions

VII. Taxpayer Entitled to Deduction

A. Introduction

B. Nonstatutory Principles

1. In General

2. Constructive Deductions

a. In General

b. Agency

(1) In General

(2) Relationship to Assignment of Income Doctrine

(3) Specific Situations

(a) Partnerships

(b) Corporations and Shareholders

(c) Sellers and Purchasers

c. Reimbursement

d. Sham Entities

e. Corporate Capital Transactions

3. Trade or Business and For-Profit Activity Expenses

a. In General

b. Employers and Employees

c. Independent Contractors

d. Corporations, Promoters, Shareholders and Officers

(1) Shareholder's Payment of Corporation's Expenses

(a) In General

(b) Expenses Treated As Corporation's

(c) Treatment of Nondeductible Amounts Paid by Shareholders

(d) Scope of Restriction

(e) Payment to Protect Shareholder

(i) In General

(ii) Determination of Purpose for Payment

(f) Payments by Shareholder As Promoter

(g) Payments After Corporate Liquidation

(h) Payments While Corporate Charter Is in Suspense

(i) Former Shareholders

(2) Officer's Payment of Corporation's Expenses

(a) In General

(b) Expenses Treated as Corporation's

(c) Scope of Restriction

(d) Payments to Protect Officer

(3) Corporation's Payment of Shareholder's Expenses

(a) In General

(b) Shareholder Property

(c) Shareholder Stock Transfers

(d) Expenses of Predecessor Partnership of Shareholders

(e) Jointly Incurred Expenses

(f) Shareholder Derivative Suits

(4) Corporation's Payment of Officer's Expenses

(5) Corporation's Payment of Bondholder's Expenses

(6) Corporation's Payment of Subsidiary's and Affiliate's Expenses

(a) Operating Expenses

(b) Compensation

(c) Warranty Expenses

(d) Equity Transactions

(7) Subsidiary's Payments to Parent

(8) Corporation's Payment of Predecessor's Expenses

(9) Corporation's Payment of Another Corporation's Expenses

e. Unincorporated Association

f. Partnerships and Partners

g. Partnership's Payment of Corporation's Expenses

h. Landlords and Tenants

i. Tenants in Common

j. Trusts, Grantors, and Beneficiaries

k. Estates, Fiduciaries, and Beneficiaries

l. Individual's Payment of Another Person's Expenses

(1) In General

(2) Expenses of Contesting Taxes

4. Interest

a. In General

b. Personal Liability

(1) In General

(2) Guarantees

(3) Transferee Liability Situations

(4) Joint Liability

(5) Spouses

c. Indebtedness Secured by Taxpayer's Property

(1) In General

(2) Beneficial or Equitable Ownership

(3) Condominiums

(4) Life Insurance Policies

d. Sellers and Purchasers

e. Corporations and Shareholders

(1) Corporation's Interest Paid by Shareholder

(2) Shareholder's Interest Paid by Corporation

(3) Officer's Interest Paid by Corporation

(4) Corporation's Payment of Interest on Subsidiary's Debt

(5) Subsidiary's Payment of Parent Corporation's Debt

(6) Corporation's Payment of Interest on Predecessor's Debt

f. Landlords and Tenants

g. Trusts, Fiduciaries, and Beneficiaries

h. Partners and Partnerships

5. Taxes

a. In General

(1) Imposition of Economic Burden of the Tax

(2) Effect of Contract

b. Payment Through Agent

c. Payments on Behalf of Corporations

d. Real Property

e. Spouses

f. Trusts and Estates

g. Banks and Depositors

h. Substantiation

6. Losses

a. In General

b. Lack of Ownership

(1) In General

(2) Property Under Contract of Sale

(3) Determination of Ownership

c. Corporations and Shareholders

(1) Corporate Activities

(a) Separate Business Operations

(b) Separate Property and Assets

(c) Formalities of Incorporation

(2) Shareholder Activities

(a) In General

(b) Corporation as Conduit

(c) Shareholder Assumption of Corporate Business

(3) Related Corporations

(a) Subsidiaries

(b) Reorganizations

d. Estates and Trusts

(1) Beneficiaries

(2) Grantors

(3) Decedents

e. Life Tenants

f. Joint Owners

g. Lessors and Lessees

7. Depreciation and Section 179 Expense Deductions

a. In General

(1) Burden of Risk of Economic Loss

(2) Capital Investment

(3) Rights to Income from Another's Property

b. Loss of Ownership

(1) Governmental Seizure

(2) Property Transferred to Public Use

c. Use by Others

d. Placement on Property of Others

e. Property Owned by Others

f. Corporations, Shareholders, and Subsidiaries

g. Purchasers and Sellers

(1) In General

(2) Default and Rescission

(3) Period Preceding Ownership

h. Lessors and Lessees

(1) In General

(2) Shifting of Burden of Loss Risk to Lessee

(3) Leasehold Improvements

(4) Acquisition of Lessor's Interest by Lessee

i. Life Estates and Remainders

j. Trusts and Estates

k. Determination of Taxpayer Entitled to Depreciation

8. Charitable Contribution Deductions

a. In General

b. Property Contributions

c. Corporate Contributions

9. Medical Expense Deductions

10. Legal and Professional Fees

C. Statutory Provisions Relating to Assignment of Deductions

1. Related Party Reallocation

a. IRS Reallocation of Deductions Among Related Parties

b. IRS Reallocation of Deductions of Personal Service Corporations

c. IRS Reallocation of Reinsurance Agreement Deductions

2. Corporate Transactions

a. Deductions Transferable in Certain Corporate Acquisitions

(1) In General

(2) Qualified Acquisition

(3) Specified Deductions

b. Limitation on Transfer of Deductions Following Ownership Change

(1) In General

(2) Affected Corporations and Deductions

(3) Limitation Amount

(4) Ownership Change

c. Limitation on Use of Preacquisition Losses

(1) In General

(2) Scope of Limitation

(3) Preacquisition Losses

(4) Recognized Built-In Gains

d. Qualified Subsidiary of Tax-Exempt Real Property Entity

(1) In General

(2) Qualified Subsidiary

(3) Tax-Exempt Real Property Entity

(4) Qualified Organization

e. Qualified Real Estate Investment Trust Subsidiaries

3. Trusts and Estates

a. Deductions of Grantor Trusts

(1) In General

(2) Conditions Under Which Grantor Trust Rules Apply

b. Excess Deductions of Estates and Trusts

4. Entities and Members

a. Partnerships

(1) In General

(2) Substantial Economic Effect

(3) Contributed Property

(4) Family and Other Partnerships

(a) In General

(b) Recognition as Partner

(c) Allocation of Deductions

(d) Purchase of Partnership Interest by Family Members

(5) Retroactive Allocations

b. S Corporations

5. Provisions Relating to the Deduction of Taxes

a. Apportionment of Real Property Taxes

(1) Introduction

(2) The Apportionment Formula: Real Property Tax Year

(3) Scope of the Apportionment Rule

b. Taxes of Shareholder Paid by Corporation

c. Cooperative Housing Corporation Shareholders

VIII. Nuclear Decommissioning Expense Deductions

A. In General

1. Deductible Amounts

2. Effective Dates of § 468A and Regulations Thereunder; Transition Rule

B. Nuclear Decommissioning Costs

1. In General

2. Exceptions

C. Eligible Taxpayer

1. In General

2. Direct Ownership Interest

3. Qualifying Leasehold Interest

4. Qualified Experimental Nuclear Facility Interest

D. Amount Limitation

1. Taxable Years Beginning After 2005

2. Taxable Years Beginning Before 2006

a. In General

b. Requirements for Inclusion in Cost of Service

c. Multiple Power Plants

d. Retroactive Changes

3. Deemed Payment Rules

4. Ruling Amount

5. Schedule of Ruling Amounts

a. In General

b. Funding Period

(1) In General

(2) Estimated Dates (Pre-2006 Tax Years)

c. Nuclear Decommissioning Costs Allocable to Fund

(1) In General

(2) Total Estimated Cost of Decommissioning

(3) Taxpayer's Share

(4) Qualifying Percentage (Tax Years Beginning Before 2006)

(a) In General

(b) Estimated Period for Which Fund Is in Effect

(c) Estimated Useful Life of Power Plant

d. Computational Premises

(1) In General

(2) Alternative Formula or Method

(3) Formula Method

(4) Rates by More than One Public Utility Commission (Tax Years Beginning Before 2006)

e. Procedure

(1) In General

(2) Limitation (Tax Years Beginning Before 2006)

(3) Manner of Requesting Schedule

(a) In General

(b) Number and Scope of Requests

(c) Noncompliance

(4) Information Required

(a) Tax Years Beginning After 2005

(b) Tax Years Beginning Before 2006

(5) IRS Procedures

(6) Mandatory Review

(a) In General

(b) Alternative Formula or Method

(c) License Renewal or Public Utility Commission Action

(i) In General

(ii) Procedure

(d) Procedural Compliance

(7) Elective Review

(8) Payments Before Receipt of Schedule of Ruling Amounts

(a) In General

(b) Ruling Amount Exceeding Taxpayer Proposal

(c) Ruling Amount Less Than Taxpayer Proposal

f. Level Funding Limitation

E. Taxable Year Limitation

F. Nuclear Decommissioning Reserve Fund

1. In General

2. Taxation of Fund

a. In General

b. Modified Gross Income

(1) Excluded Income

(2) Deductions Allowed

(3) Distributions of Property by Fund

(4) Taxable Period

c. Procedural Matters

(1) In General

(2) Return Filing

(a) Obligation

(b) Fund Existence

(c) Due Date

(3) Employer Identification Number

(4) Estimated Tax Payments

(5) Tax Deposits

(6) Additions to Tax

3. Disqualification

a. In General

b. Qualification Requirements

(1) Establishment

(a) In General

(b) When Separate Funds Are Required

(c) Asset Pooling

(d) Limitation on Number of Funds

(2) Contribution Limitations

(3) Limitations on Use of Fund

(a) In General

(b) Administrative Costs and Other Incidental Expenses

(c) Trust Provisions

(4) Limitations on Self-Dealing

(a) In General

(b) Self-Dealing

(i) In General

(ii) Exceptions

(iii) Disqualified Person

c. Excess Contribution Withdrawal Exception

(1) In General

(2) Excess Contribution

d. Effect of Disqualification

(1) Effect on Fund

(2) Effect on Taxpayer

(a) Gross Income

(b) Loss of Tax Benefits

4. Termination

a. In General

b. Effect of Termination

(1) Effect on Fund

(2) Effect on Taxpayer

(a) Gross Income

(b) Loss of Tax Benefits

c. Substantial Completion of Decommissioning

(1) In General

(2) Exception

(3) Substantial Completion Date

G. Nuclear Power Plant

H. Public Utility Commission

I. Disposition of Interest in Nuclear Power Plant

1. In General

2. Qualification Requirements

3. Consequences

4. Impact on Schedule of Ruling Amounts

a. Transferor

b. Transferee

J. Election to Apply § 468A

1. In General

2. Procedure

3. Election Statement

K. Special Transfers to Qualified Funds

1. In General

2. Deduction

a. In General

b. Previously Deducted Amounts

c. Transfers of Qualified Funds

d. Tax Consequences

3. Schedule of Deduction Amounts

a. In General

b. Special Transfers in Multiple Tax Years

c. Special Transfers of Partial Interest

d. Manner of Requesting Schedule

(1) In General

(2) Number and Scope of Requests

(3) Noncompliance

(4) Information Required

(5) Statement Required

(6) IRS Procedures

Working Papers

Working Papers

Table of Worksheets

Worksheet 1 Finding List of Related Tax Management Portfolios

Worksheet 2 Client Letter - Recordkeeping for Personal Income Tax Purposes

Worksheet 3 Client Letter - Year-End Tax Planning - Identifying Often-Overlooked Deductions and Accelerating or Delaying Payment of Deductible Expenses

Worksheet 4 Client Letter - Medical and Dental Expenses

Worksheet 5 Client Letter - Casualty and Theft Losses

Worksheet 6 Standard Deduction Tables

Worksheet 7 Personal Exemption Tables

Worksheet 8 Staff of the Joint Comm. on Tax'n, Description and Technical Explanation of the Conference Agreement of H.R. 6, Title XIII, “Energy Tax Incentives Act of 2005” (JCX-60-05) (7/28/05) (description of amendments to § 468A)





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