Entries by TAX

Disregarded Entities and Partnerships

By John G. Hodnette Single-member LLCs and grantor trusts are both entities that exist for state law purposes but are disregarded for federal income tax purposes. These entities are commonly known as disregarded entities or DREs. The ownership of partnership interests by a disregarded entity creates the question of who the partner really is. A […]

Casualty Losses Under Sections 162 or 165(c)(2)

By John G. Hodnette The Internal Revenue Code (“IRC”) sometimes provides multiple avenues for a taxpayer to obtain a deduction depending on how the taxpayer characterizes the loss. One example is a casualty loss deducted under either Section 162 or Section 165. Although these two sections may both offer a deduction for the same loss, […]

The NOL Carryback Rules Under the CARES Act

By John G. Hodnette On March 27, the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act introduced a number of new provisions to assist businesses and individuals during the COVID-19 pandemic. One such provision adjusts the rules of net operating loss (“NOL”) carrybacks. Before 2018, NOLs of a business or individual could be carried back […]

The Tax Implications of Three Programs Created by the CARES Act

By John G. Hodnette The landscape of the United States has changed in the past weeks as COVID-19 continues to sweep across our nation. The Federal government attempted to mitigate the economic damage of the virus on March 27 with the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act. Although the programs created by the […]


By Herman Spence III On November 7, 2019, John Hodnette posted an article on the Tax Section’s blog regarding employee educational fringe benefits.  As noted in the article, Section 132(a)(3) provides an exclusion from gross income for working condition fringes.  A working condition fringe is any property or service provided to an employee to the […]


By Keith A. Wood This is the first of two installments of this article.  The second installment will soon be posted on the Tax Section blog. I.     Damages for Emotional Distress Not Excludable from Taxable Income Unless Directly Associated with Physical Injury. A.     Background. Section 104(a)(2) provides an exclusion from gross income […]

S Corporations: Dealing with Accumulated Earnings and Profits

Please send articles for the Tax Section blog to: Herman Spence at HSpence@robinsonbradshaw.com. By Kerri L.S. Mast C corporation income is generally subject to two levels of taxation.  It is taxed at the corporate level when earned and at the shareholder level when distributed.  An S corporation, on the other hand, generally is not taxed […]

Pro Bono Opportunity

By Helen Herbert Are you looking for a pro bono opportunity where you can use your tax expertise?  The NCBA Tax Section is looking for tax attorneys to train selected military personnel to be tax return preparers through the Military Volunteer Income Tax Assistance (VITA) Program. The Military VITA Program is designed to assist US […]