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Archive for June, 2012

Today we conclude our three-part look at Revenue Ruling 84-111 and the methods available for incorporating a partnership. To summarize what we’ve covered so far:

Method 1: “Assets Over”

  • Partnership transfers assets to the newly formed corporation in exchange for stock. Partnership then liquidates, distributing stock to partners.
  • Partnership recognizes no gain or loss on the transfer of assets and liabilities under Section 351 unless the liabilities transferred exceed the tax basis of the transferred assets, in which case the partnership recognizes gain under Section 357(c).
  • As a result, if the liabilities exceed the tax basis of the assets, the “Assets Over” Method may not be the right one for you.
  • Corporation takes a basis in the assets equal to the partnership’s basis in the assets under Section 362.
  • Partnership takes a basis in the stock received equal to the partnership’s basis in its assets less the liability relief under Section 358.
  • Partnership then liquidates, with partners taking a basis in the stock received equal to their basis in the partnership under Section 732 less their share of debt relief under Section 752.

Method 2: “Assets Up

  • Partnership liquidates first, and then partners transfer assets and liabilities to the corporation in exchange for stock.
  • Upon liquidation, partners recognize gain if cash distributed exceeds their outside basis in the partnership under Section 731.
  • Under Section 732, partners take a basis in the assets distributed equal to their outside basis less any cash received.
  • Upon transfer of assets and liabilities to the corporation, no gain or loss is recognized under Section 351.
  • Any potential Section 357(c) gain can be avoided by contributing additional assets necessary to equalize asset basis with liabilities.
  • Corporation takes a basis in the assets received equal to the partners’ basis in those assets under Section 362.
  • Partners take a basis  in the stock received equal to their basis in the assets less any liabilities relieved of.

Today we take on the third and final method provided for in Revenue Ruling 84-111, in which the partners merely transfer their partnership interests to the newly formed corporation in exchange for stock in a Section 351 transfer. I apologize for the less than formal background, but circumstances beyond my control (read: the European Championship semifinals) forced me to record today’s video from a different location.

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Sounds strange, but it’s true. After poring over Chief Justice Roberts’ opinion, the primary reason nearly every American will be required to own health insurance starting in 2014 or else be required to pay a penalty…err….tax to the IRS is because the required payment to the IRS under I.R.C. § 5000A is BOTH a penalty and a tax.

Allow me to explain.

Before the Supreme Court could determine whether the individual insurance mandate is constitutional, the justice’s first had to wrestle with the “Anti-Injunction Act.” The Anti-Injunction Act essentially provides that no suit may be brought against the government for imposing a tax until after the tax has been paid, at which point the payor could sue for refund. The purpose of this rule is obvious: to allow the government to impose revenue raising taxes and not have to fight through an endless string of lawsuits before they may begin to collect their revenue.

As a result, if the penalty imposed under I.R.C. § 5000A for failure to own health insurance were deemed to be a “tax” for purposes of the Anti-Injunction Act, the Supreme Court would be effectively barred from ruling on the constitutionality of the Patient Protection Act until 2015: the year taxpayers would have begun making payments on their tax return and could thus sue for refund. The Supreme Court, however, found that for these purposes — and as we’ll discuss later, only for these purposes — the amounts paid under I.R.C. § 5000A are a “penalty,” rather than a tax.

The Anti-Injunction Act applies to suits “for the purpose of restraining the assessment or collection of any tax.” §7421(a) (emphasis added). Congress, however, chose to describe the “[s]hared responsibility payment” imposed on those who forgo health insurance not as a “tax,” but as a “penalty.” §§5000A(b), (g)(2). Congress’s decision to label this exaction a “penalty” rather than a “tax” is significant because the Affordable Care Act describes many other exactions it creates as “taxes.”

Moving on to the highly-anticipated part of the decision, the Supreme Court was left to determine if requiring taxpayers to obtain health insurance was constitutional under two alternative arguments:

1. Did Congress have the power to enact the mandate under the Commerce Clause?

2. In the alternative, can the mandate be viewed not as an order to acquire insurance, but rather a tax to be borne by those who forego insurance? And if so, is such a tax within the powers of Congress?

Commerce Clause Argument:

The Supreme Court determined — by a 5-4 vote — that the individual insurance mandate was not constitutional under the Commerce Clause. The primary factor in the determination was that the Commerce Clause allows Congress to regulate commerce, not to compel Americans to enter into commerce they might otherwise refrain from:

The individual mandate, however, does not regulate existing commercial activity. It instead compels individ­uals to become active in commerce by purchasing a product, on the ground that their failure to do so affects interstate commerce. Construing the Commerce Clause to permit Con­gress to regulate individuals precisely because they are doing nothing would open a new and potentially vast do­main to congressional authority. Every day individuals do not do an infinite number of things. In some cases they decide not to do something; in others they simply fail to do it. Allowing Congress to justify federal regulation by pointing to the effect of inaction on commerce would bring countless decisions an individual could potentially make within the scope of federal regulation, and—under the Government’s theory—empower Congress to make those decisions for him.

To illustrate the Pandora’s box that could be opened by allowing Congress to initiate commerce, Justice Roberts used the following example:

Indeed, the Government’s logic would justify a manda­tory purchase to solve almost any problem. To consider a different example in the health care market, many Americans do not eat a balanced diet. That group makes up a larger percentage of the total population than those without health insurance. The failure of that group to have a healthy diet increases health care costs, to a greater extent than the failure of the uninsured to pur­chase insurance. Those in­creased costs are borne in part by other Americans who must pay more, just as the uninsured shift costs to the insured.  Under the Gov­ernment’s theory, Congress could address the diet problem by ordering everyone to buy vegetables. That is not the country the Framers of our Constitution envisioned.

While the government posed the argument that all Americans — whether young, old, healthy, sick, insured or uninsured — will at some point need health insurance, and thus are all “active” in the health insurance marketplace, the Supreme Court was not convinced:

The Government repeats the phrase “active in the mar­ket for health care” throughout its brief, but that concept has no constitutional significance. An individual who bought a car two years ago and may buy another in the future is not “active in the car market” in any pertinent sense. The phrase “active in the market” cannot obscure the fact that most of those regulated by the individual mandate are not currently engaged in any commercial activity involving health care, and that fact is fatal to the Government’s effort to “regulate the uninsured as a class.” Everyone will likely participate in the markets for food, clothing, transportation, shelter, or energy; that does not authorize Congress to direct them to purchase particular products in those or other markets today. The Commerce Clause is not a general license to regulate an individual from cradle to grave, simply because he will predictably engage in particular transactions.

Taxing Powers Argument

Having held that the individual insurance requirement was unconstitutional under the Commerce Clause, the fate of Obamacare rested on whether the mandate could be imposed as part of Congress’ taxing powers.

Before it could address this argument, however, the justice’s had to be willing to look at the mandate another way. Rather than reading the requirement to obtain heath insurance or pay a tax as an “order,” it should be viewed as simply imposing a tax on those who do not buy the product. The court was willing to do so:

Under the mandate, if an individual does not maintain health insurance, the only consequence is that he must make an additional payment to the IRS when he pays his taxes. See §5000A(b). That, according to the Government, means the mandate can be regarded as establishing a condition—not owning health insurance—that triggers a tax—the required payment to the IRS. Under that theory, the mandate is not a legal command to buy insurance. Rather, it makes going without insurance just another thing the Government taxes, like buying gasoline or earn­ing income. And if the mandate is in effect just a tax hike on certain taxpayers who do not have health insurance, it may be within Congress’s constitutional power to tax.

Next, in order to determine whether the mandate was within the taxing powers of Congress, the Supreme Court — just pages after holding the mandate to be a “penalty” for purposes of the Anti-Injunction Act — would have to be convinced that the payment made to the IRS under I.R.C. § 5000A was actually a “tax” for constitutional purposes. Surprising many, the court made just that leap:

The exaction the Affordable Care Act imposes on those without health insurance looks like a tax in many re­spects. The “[s]hared responsibility payment,” as the statute entitles it, is paid into the Treasury by “tax­payer[s]” when they file their tax returns. 26 U. S. C. §5000A(b). It does not apply to individuals who do not pay federal income taxes because their household income is less than the filing threshold in the Internal Revenue Code. §5000A(e)(2). For taxpayers who do owe the pay­ment, its amount is determined by such familiar factors as taxable income, number of dependents, and joint filing status. §§5000A(b)(3), (c)(2), (c)(4). The requirement to pay is found in the Internal Revenue Code and enforced by the IRS, which—as we previously explained—must assess and collect it “in the same manner as taxes.” This process yields the essential feature of any tax: it produces at least some revenue for the Government. Indeed, the payment is expected to raise about $4 billion per year by 2017.

Thus, the Supreme Court was able to reconcile calling the mandate a “penalty” for purposes of the Anti-Injunction Act, but a “tax” for purposes of its constitutionality:

It is of course true that the Act describes the payment as a “penalty,” not a “tax.” But while that label is fatal to the application of the Anti-Injunction Act, supra, at 12–13, it does not determine whether the payment may be viewed as an exercise of Congress’s taxing power. It is up to Con­gress whether to apply the Anti-Injunction Act to any particular statute, so it makes sense to be guided by Con­gress’s choice of label on that question. That choice does not, however, control whether an exaction is within Con­gress’s constitutional power to tax.

In addition, because Congress left it up to us, the taxpayers, to decide whether to obtain insurance or pay the tax, with no potential for punitive sanctions or criminal prosecution, it carried the hallmarks of a constitutional tax.

And that’s how we got to where we are today: with an elated President Obama, a despondent Rush Limbaugh, and much of America shaking their heads and trying to make sense of how the same payment can be both a “penalty” and  a “tax.”

Click for a PDF of the entire opinion —  Supreme Court opinion — including the dissenting opinion of the four liberal justices who believed the mandate was within the powers of the Commerce Clause, as well as the dissenting opinion of the four conservative justices who found the mandate unconstitutional under both arguments.

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Proving once again that you’re best served ignoring any predictions we make here on Double Taxation, the Supreme Court defied expectations today and voted by a 5-4 margin to uphold the individual insurance mandate in the Patient Protection and Affordable Care Act as constitutional. Conservative Chief Justice John Roberts voted in support of the mandate, joining the four liberal justices to provide the needed majority.

As far as whether everything in the Act stands, we’ll have to parse through the 193-page decision before we can comment on that. Should make for a fun Thursday night.

 

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Just as the Seventh Circuit did four months ago in Rolfs v. Commissioner,  today the Tax Court disallowed the charitable contribution deduction claimed by a taxpayer who donated his home to the local fire department for use in their drills, with the understanding that the home would be burned down to clear way for a new residence.

In Patel v. Commissioner, 138 T.C. 23 (2012), however, the Tax Court reached this conclusion via a different approach then it had in its initial decision in Rolfs; between the two methodologies, there leaves little ground for future taxpayers to support a charitable contribution deduction in this scenario, and the only previous authority to allow such a deduction — Scharf v. Commissioner – is effectively dead.

If you recall, in Rolfs, neither the Tax Court nor the Seventh Circuit  argued that the contribution of a home to a fire department did not qualify as a charitable contribution; to the contrary, both courts agreed that all of the statutory requirements were in place. The issue, rather, was one of value.  

The Seventh Circuit held that the value of the home had to take into consideration its imminent demise:

When a gift is made with conditions, the conditions must be taken into account in determining the fair market value of the donated property. As we explain below, proper consideration of the economic effect of the condition that the house be destroyed reduces the fair market value of the gift so much that no net value is ever likely to be available for a deduction, and certainly not here. What is the fair market value of a house, severed from the land, and donated on the condition that it soon be burned down? There is no evidence of a functional market of willing sellers and buyers of houses to burn.

Based on these restrictions, the value of the home was less than the $10,000 benefit the Rolfs derived from having the fire department do their demolition work for them, and thus the deduction was denied under the “quid pro quo” rules.

To the contrary, in Patel, the IRS and the Tax Court attacked the propriety of the taxpayer’s charitable contribution deduction under I.R.C. § 170. The root of the denial was grounded in I.R.C. § 170(f)(3), which denies a charitable contribution deduction for certain contributions of partial interests of property:

(3) Denial of deduction in case of certain contributions of partial interests in property.–

(A) In general.–In the case of a contribution (not made by a transfer in trust) of an interest in property which consists of less than the taxpayer’s entire interest in such property, a deduction shall be allowed under this section only to the extent that the value of the interest contributed would be allowable as a deduction under this section if such interest had been transferred in trust. For purposes of this subparagraph, a contribution by a taxpayer of the right to use property shall be treated as a contribution of less than the taxpayer’s entire interest in such property.

The purpose of the “partial interest” rule is to prevent a taxpayer from deriving a double benefit: once when using the property, and again in the form of a subsequent contribution deduction. Or perhaps to better illustrate it, imagine a building owner who owns 10 apartments. If he grants the use of one of the ten apartments rent-free to a charitable organization and is permitted a charitable contribution for the foregone rent, he would benefit twice: once in the form of reduced taxable income by foregoing the rent, and again for a charitable contribution for the foregone rent.

To answer the question as to whether the Patels granting of the use of their home to the fire department was the granting of a partial interest in the property, the Tax Court looked to Virginia state law, which provides that the term “land” includes any home or building on the property.

Based on this definition, because the Patels contributed an interest in a building that is part of the underlying land under State law but retained all title to and interest in the remaining land, the Patels donated less than their entire interest in the land. As a result, the Patels would not be allowed a charitable contribution deduction unless the donated interest fell within the following exceptions of section 170(f)(3)(B):

 (B) Exceptions.–Subparagraph (A) shall not apply to–

(i) a contribution of a remainder interest in a personal residence or farm,

(ii) a contribution of an undivided portion of the taxpayer’s entire interest in property, and

(iii) a qualified conservation contribution.

 The Tax Court made quick work of the first and third exclusions, holding that the contribution of the home was neither the contribution of a remainder interest in a personal residence (because the fire department never had any interest in the house) nor a qualified conservation contribution (because the use by the fire department did not qualify as “conservation.”)

The crux of the decision, however, was whether the contribution of the home was a contribution of an undivided portion of the Patels’ entire interest in the home. The regulations provide the following guidance:

An undivided portion of a donor’s entire interest in property must consist of a fraction or percentage of each and every substantial interest or right owned by the donor in such property and must extend over the entire term of the donor’s interest in such property and in other property into which such property is converted. For example * * * . * * * If a taxpayer owns 100 acres of land and makes a contribution of 50 acres to a charitable organization, the charitable contribution is allowed as a deduction under section 170.[i]

In reaching its conclusion to deny the deduction, the Tax Court held that the transfer of the home was not the transfer of an undivided interest in the property, because upon closer inspection, there was not a transfer of any part of the Patels’ interest in the home, because the benefits and burdens of owning the home were never transfered to the fire department. Instead, the court likened the use of the building by the fire department to a license:

 Granting a fire department the right to destroy the building while conducting training exercises on the property is not a conveyance of ownership, title, or possession of the building or any other property interest in the building or the Vienna property. Rather it is a mere license to use the property. Granting a fire department the right to conduct training exercises on one’s property and destroy a building thereon by fire grants the fire department the right “to do an act which without such authority would be illegal, a tort, or a trespass”.

 The fire department does not acquire the right to eject the landowner from the building and cannot force the landowner to allow the destruction of the building should he change his mind before the house has been destroyed. The fire department has acquired a mere revocable license that does not vest any property interest in the fire department.  

 It’s important to note, the Tax Court was not unified in its opinion. Justice Gale dissented, taking umbrage with the majority’s contention that the donation of the home to the fire department was merely a license. Gale argued that in a typical license arrangement, there is an understanding that the property will be returned to the grantor of the license subject to normal wear and tear. By permitting the fire department to destroy the building, the Patels formally transferred their property interests to the fire department. Once the fire department destroyed the home, Gale posited, the Patels retained no substantial interest in the home, and thus would have transferred an undivided interest in the property.

Justice Gales did concede, however, that even if the donation were permitted under statute, there remains the question of value to deal with as established in Rolfs; the Patels would be required to show that the value of the home — using the Rolfs methodology — exceeded the benefit they derived from the demolition.

Even with Justice Gale’s dissent, the Tax Court’s decision in Patel serves to add another round of ammunition to the Service’s attack on this type of charitable contribution deduction. In light of these two Tax Court decisions and the Seventh Circuit’s affirmation in Rolfs, taxpayers would be wise not to tempt fate and pursue this deduction.


[i] Treas. Reg. §1.170A-7(b)(1)(i)

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As a divided nation waits with breathless anticipation for the Supreme Court to rule on Obamacare, we figured it might be helpful to remind everyone exactly what hangs in the balance from a tax perspective.

Aside from establishing a precedent regarding the constitutionality of a mandate requiring all Americans to obtain health insurance, and –as a byproduct — potentially dealing a staggering uppercut to President Obama’s re-election campaign, the Supreme Court will determine the fate of the following tax provisions tomorrow: 

  • Beginning in 2014, I.R.C. § 5000A would require taxpayers to purchase or retain health insurance that qualifies as minimum essential coverage, and to report this information on their federal tax returns, subject to certain codified exceptions. If the taxpayer fails to maintain adequate insurance, a monthly “penalty” is imposed equal to the greater of a flat dollar amount (phased in starting at $95 in 2014) or a percentage of the taxpayer‘s income (phased in starting at 1% in 2014). This would obviously cease to be effective should the individual mandate be struck down.

The fate of the final three bullet points depend on two factors: First, the Supreme Court would have to rule the individual mandate unconstitutional. In addition, the court would also have to conclude that the remaining provisions of the Patient Protection and Affordable Health Care Act cannot be severed from the individual mandate, and must be struck down.

  • Starting in 2014, pursuant to I.R.C. § 4980H, applicable large employers must provide minimum essential coverage to each full-time employee and their dependents. Failure to comply with the employer mandate will result in a penalty equal to one-twelfth of $3,000 for each month multiplied by the applicable number of full-time employees. In general, an “applicable large employer” is any employer with a work force in excess of fifty full-time employees.
  • Higher Medicare taxes will be imposed upon wealthy taxpayers beginning in 2013. Section 3101(b)(2)will be amended to include an additional tax of 0.9 percent on all income in excess of $200,000 or $250,000 for joint filers.
  • 2013 will also add to the Code I.R.C. § 1411, which creates a 3.8 percent Medicare tax on investment income in excess of $250,000 for joint filers, $125,000 for married filing separately, and $200,000 ―in any other case.

If you’re curious for my predictions — and if you are, your lonliness saddens me —  I’m fairly confident that the individual mandate is doomed, but I do believe it will be severed from the remaining provisions, and the other tax aspects of Obamacare will remain.

Prior covererage here, here, and here.

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Beating the IRS in Tax Court ain’t easy.  But if you want to have a chance, as difficult as this may be, you’ve got to employ a touch of common sense.

In Carmickle v. Commsisioner, T.C. Summary Opinion 2012-60 (2012), Sam Carmickle owned an apartment building as well as a home. During 2006, Carmickle sold the apartment building for a gain of $90,000, but excluded the gain from his tax return on the premise that it was excludible under I.R.C. § 121.

As you may recall, I.R.C. § 121 excludes up to $500,000 of gain on the sale of a taxpayer’s principal residence, provided the taxpayer both owned and used the home as his principal residence in 2 of the previous 5 years.

Unfortunately for Carmickle, however, there was absolutely no evidence that he lived in the apartment building. He used the address of a home located in Chicago as his mailing address, parked his vehicles there, and most damning, he claimed a $20,000 home office deduction for a space in the Chicago home.

As you might imagine, the IRS denied the application of the I.R.C. § 121 exclusion to the gain on the sale of the apartment, holding Carmickle responsible for the full amount of the $90,000 gain. The Tax Court agreed, handing down a 20% underpayment penalty for good measure.  

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The IRS will soon be publishing Revenue Procedure 2002-29, which will add some clarity to the risks of making a I.R.C. § 83(b) election while also providing some helpful sample language. Let’s get right to the Q&A:

Q: Remind me what I.R.C. §  83 says?

A: That’s really not a question, it’s more of a directive, but fine. We’ve covered it here and here, but in general, I.R.C. § 83 provides that if you provide services for someone (whether past, present, or future) and that person compensates you by paying you in property, the excess of the FMV of the property over the amount you paid to acquire it is taxed as compensation income.

Example 1: You provide services for your employer. Your employer, in turn, pays you in unrestricted, freely transferable stock valued at $100 and requires you to pay $0 to obtain the stock. Under I.R.C. § 83, you will recognize ordinary income of $100 upon the receipt of the stock.

Q: So then what’s a Section 83(b) election?

A: Here’s the catch. Under I.R.C. § 83, the service provider (you) are only taxed on the property you receive when that property is EITHER:

1. no longer subject to a substantial risk of forfeiture, or

2. freely transferable.

This is a concept that confuses many tax advisers. Property must be subject to BOTH conditions in order for the recipient to defer the recognition of taxable income. The moment the property either becomes transferable or no longer subject to a substantial risk of forfeiture, the recipient must recognize taxable income.

Q: So you get to defer the income? Isn’t that a good thing?

A: Contrary to popular opinion, income deferral — like Radiohead and Johnny Depp  — isn’t always great. Here’s the thing…under the general rule of I.R.C. § 83, when the property becomes either freely transferable or no longer subject to a substantial risk of forfeiture, the service recipient (you) will be taxed on the FMV of the property at that time. Thus, if the value has increased substantially from the date it was first granted to you until the date the restrictions lapse, you will pay for your deferral with an increased income recognition.

Example 2: If the $100 in stock in Example 1 was subject to a substantial risk of forfeiture — i.e., you were required to remain employed for 2 years in order to “vest” in the property — you would not be taxed upon receipt of the $100 in stock in year 1. Instead, your income would be deferred until you vested in year 3. At that point, if the value of the stock had increased to $400, you would be required to recognize $400 of compensation income, as opposed to the $100 in the previous example.

Q: So where does the election come in?

A: Section 83(b) and Treas. Reg. § 1.83-2(a) permit the service provider (you) to elect to include the excess of the FMV of the property at the time of transfer over the amount paid for the property as compensation for services at the time of the transfer, rather than when the restrictions lapse. Thus, in Example 2, even though the stock did not vest until year 3, you could elect under I.R.C. § 83(b) to include the $100 in income in year 1.

Q: Why would you choose to accelerate income?

A: Because in some situations, as illustrated above, if you don’t make the election, you will recognize more ordinary income when the property vests if the FMV of the property increases. In other words, when you make an I.R.C. § 83(b) election, you are betting that the value of your nonvested property will increase. By making the election, you are capping your ordinary income at the FMV on the date of transfer. Any subsequent appreciation will only be recognized upon a subsequent disposition of the property, likely as capital gain.

Q: You said something in the intro about risks. What’s the downside?

A: The downside is obvious, and quite painful. If you make an I.R.C. § 83(b) election to include the FMV of restricted property in income at the date of grant and the value subsequently decreases, well…then you just voluntarily accelerated more income than necessary. It is, as I said, a gamble.

Q: Any other risks?

A: There sure are. Say you don’t actually vest in the property; for example, you don’t put in the two years required to vest in the stock in the illustration above. The regulations provide that you don’t get a deduction for the amount you voluntarily took into income; rather, you may recognize a loss equal to the amount paid for the property less any amount realized on the sale.

To illustrate just how painful this can be, assume you made the election to include the stock worth $100 in income in year 1, expecting the value to increase before you vested in year 3. You decide to leave the company in year 2, however, and never vest, forfeiting the property back to your employer for no consideration. Your loss is limited to $0 (the amount you paid for the stock), even though you included $100 in taxable income. Ouch.

Q: When/How do I make the election?

A: An election made under I.R.C. §  83(b) must be filed with the Internal Revenue Service no later than 30 days after the date that the property is transferred to the service provider. This is done so as not to give you the benefit of too much in the way of hindsight as to the change in value of the restricted property.

The election is made by filing a copy of a written statement with the Internal Revenue Service office with which you file your return. In addition, you’re required to submit a copy of such statement with your income tax return for the taxable year in which such property was transferred. The statement must be signed by the person making the election and must indicate the election is being made under I.R.C. §  83(b). The statement must include the following information: the name, address and taxpayer identification number of the taxpayer; a description of each property with respect to which the election is being made; the date or dates on which the property was transferred and the taxable year for which such election is being made; the nature of the restriction or restrictions to which the property is subject; the fair market value at the time of transfer of each property with respect to which the election is being made; the amount, if any, paid for such property; and a statement to the effect that copies have been furnished to other persons as provided in Treas. Reg. § 1.83-2(d).

Q: So what did Revenue Procedure 2012-29 add?

A: Not much.  The RP added some clarity, but mostly provided sample language that can be used in making the election, likely because the IRS has read your Facebook status updates and realized that rudimentary writing skills have gone the way of the dodo.

For text of the sample election, click RP 2012-29.

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