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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Location: Brea, CA

SPIFFs and income tax

Post by Arthur Rubin »

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

Post by Nikki »

http://www.autodealeradvisors.com/artic ... jsp?aid=38

Close enough to start?
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The Operative
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Re: SPIFFs and income tax

Post by The Operative »

http://www.legalbitstream.com/scripts/i ... 1f/210/doc
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Arthur Rubin
Tupa-O-Quatloosia
Posts: 1754
Joined: Thu May 29, 2003 11:02 pm
Location: Brea, CA

Re: SPIFFs and income tax

Post by Arthur Rubin »

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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