SPIFFs and income tax

Practical and Practice issues for Professionals who practice in the area of taxation. Moral, social and economic issues relating to taxes, including international issues, the U.S. Internal Revenue Code, state tax issues, etc. Not for "tax protestor" issues, which should be posted in the "tax protestor" forum above. The advice or opinion given herein should not be relied on for any purpose whatsoever. Also examines cookie-cutter deals that have no economic substance but exist only to generate losses, as marketed by everybody from solo practitioner tax lawyers to the major accounting firms.
Arthur Rubin
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SPIFFs and income tax

Postby Arthur Rubin » Tue Mar 16, 2010 1:40 am

Does anyone have a copy of Revenue Ruling 70-337. I know what the IRS wants, but it doesn't seem to be supported by the tax code or regulations, and I'm trying to convince myself that what the IRS wants is legal, even if beneficial to the client.
Arthur Rubin, unemployed tax preparer and aerospace engineer
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Nikki

Re: SPIFFs and income tax

Postby Nikki » Tue Mar 16, 2010 2:02 am


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The Operative
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Re: SPIFFs and income tax

Postby The Operative » Tue Mar 16, 2010 2:03 am

Light travels faster than sound, which is why some people appear bright, until you hear them speak.

Arthur Rubin
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Posts: 1457
Joined: Fri May 30, 2003 12:02 am
Location: Brea, CA

Re: SPIFFs and income tax

Postby Arthur Rubin » Tue Mar 16, 2010 6:37 am

Thanks, all.

I'm surprised I haven't seen tax protestors using parts of 26 CFR 31.3121 to claim that their income isn't wages, but perhaps I haven't been paying attention.
Arthur Rubin, unemployed tax preparer and aerospace engineer
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