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Section 469(c)(7) Procedure, Practice, and Regulatory Implications


Total Credits: 3 including 3 Taxes - Technical

Average Rating:
   12
Categories:
ACPEN Industry Institute |  ACPEN Tax Institute |  IRS Approved |  Tax
Faculty:
David Randall Jenkins, Ph.D.
Course Levels:
Intermediate
Duration:
3 Hours
License:

Dates


Description

My October 2016 Journal of Taxation paper, “Section 469’s Activity and Participation Conclusive Presumptions,” makes clear the Tax Court’s March 2014 Aragona Trust decision distilled previously confused rental real property trade or business activity and material participation distinctions. This paper concludes Aragona Trust is procedurally retroactive, outlines transition practices, and calls for regulatory changes.

Syllabus

Lesson 1.

Introduction

Lesson 2.

Aragona Trust is Procedurally Retroactive

Lesson 3.

Pragmatic Transitioning Practices

Lesson 4

The Call for Regulatory Change

Lesson 5

Conclusion

 

**Please Note:  If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to leighanne.conroy@acpen.com.

Basic Course Information

Learning Objectives

*Recognize the Tax Court’s March 2014 Aragona Trust decision should be correctly accorded retroactive treatment

*Recognize transition practices correctly involve amending all open-year returns that had reported Section 469(c)(7) rental real property trade or business activities inconsistent with Aragona Trust

*Recognize the Secretary of the Treasury has a duty, and the reasons therefor, to correctly revise Section 469 and 1402 regulations to be consistent with Aragona Trust’s tenets


Major Subjects

*Section 469(c)(7) rental real estate trade or business activity and material participation conclusive presumptions

*Procedural retroactivity of court decisions and application to the Tax Court’s March 2014 Aragona Trust decision

*Transitioning from pre-Aragona Trust decision real estate professional practices to Section 469(c)(7) rental real estate trade or business activity and material participation conclusive presumption practices

*Call for Section 469 and 1402 regulatory changes  


Course Materials

Faculty

David Randall Jenkins, Ph.D.'s Profile

David Randall Jenkins, Ph.D. Related Seminars and Products


David Randall Jenkins, Ph.D., received his doctorate in accounting and a master’s in accounting with an emphasis in tax from the University of Arizona. He has taught financial, managerial, and tax accounting courses at both the graduate and undergraduate levels. Dr. Jenkins is an AACSB academically qualified business school and tax professor owing to his peer reviewed journal article publications. His company, Algorithm LLC (algorithm-llc.com), is an IRS Approved Continuing Education Provider.  Dr. Jenkins may be contacted at tucjenkins@aol.com.


Additional Info

Basic Course Information

Prerequisites

This webcast is an intermediate continuing education webcast.  

It is assumed the webcast participant has successfully completed the ACPEN/BPN webcast, “Section 469’s Activity and Participation Conclusive Presumptions”


Advanced Preparation

None


Designed For

*CPAs

*Attorneys

*Enrolled Agents

*Enrolled Retirement Plan Agents

*Self-directed Retirement Plan Fiduciaries, Custodians, and Administrators  

*Self-directed Retirement Plan Account Holders

*Tax Return Preparers    


Original Recording Date

10/24/2016


Yellow Book

No


Course Developer

David Randall Jenkins


Date Added to Catalog

10/11/2016


Additional Information

Complaint Resolution Policy

Please contact Anne Taylor for any complaints.  anne.taylor@acpen.com(972-377-8199).


Official Registry Statement

Business Professionals' Network, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org


Instructional Delivery Method

Group Internet Based


Course Registration Requirements

Online Registration


Refund/Cancellation Policy

Please contact the ACPEN help desk 1-877-602-9877 or help@acpen.com if you wish to cancel your attendance for a previously purchased webcast and are requesting a refund or transfer. 


Promo Video

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Overall:      4.2

Total Reviews: 12