Ipads, iPhones, and Barter Transactions

From the hardly noticed case of Sherwin Community Painters, Inc. v. Commissioner, T.C. Memo. 2022-19, come some interesting tidbits.  First, just the facts.  Sherwin Community Painters, Inc. is a C-corporation with a single shareholder.  As its name implies, Sherwin was a painting contractor. The case arose from the Service’s disallowance of certain business deductions claimed…

S-Elections Gone Wrong

The IRS just released four separate Private Letter Rulings (“PLRs”) addressing the inadvertent termination of a taxpayer’s S-election. It is often said the devil is in the details, which is demonstrated aptly by these four PLRs.  Fortunately for the taxpayer, in each case the Service found that the terminations were inadvertent, which means the taxpayer…