Also see: In-Depth Analysis of Year-End Tax Act. (Client Letters Included).

Top Tax Developments of 2019

(Parker Tax Publishing January 2020)

In 2019, a divided federal government managed to pass new tax legislation in June with the Taxpayer First Act, and the IRS kept practitioners busy with an abundance of guidance on several key provisions of the Tax Cuts and Jobs Act of 2017 (TCJA). In addition, the fiscal year 2020 appropriations package passed by Congress, and signed into law by President Trump on December 20, contained three dozen tax extenders and numerous other tax law changes. The following is a summary of the most important tax developments of 2019.

IRS Issues Extensive Guidance to Help Clarify Calculation of the Section 199A Deduction

In January, the IRS issued eagerly anticipated guidance on the qualified business income (QBI) deduction under Code Sec. 199A in final regulations (T.D. 9847), proposed regulations (REG-134652-18), and Rev. Proc. 2019-11.

Code Sec. 199A generally provides a 20 percent deduction for qualified business income (QBI) from sole proprietorships, S corporations, partnerships, and LLCs taxed as partnerships. Thus, the calculation of QBI and, therefore, the benefits of Code Sec. 199A, are limited to taxpayers with income from a trade or business. Reg. Sec. 1.199A-1(b)(14) defines "trade or business" as a trade or business under Code Sec. 162 other than the trade or business of performing services as an employee. The final regulations also extend the definition of a trade or business beyond the Code Sec. 162 definition by treating the rental or licensing of tangible or intangible property to a related trade or business as a trade or business if the rental or licensing activity and the other trade or business are commonly controlled. The final regulations also included guidance regarding when a rental real estate enterprise qualifies as a trade or business for purposes of Code Sec. 199A (see below).

The proposed regulations in REG-134652-18 addressed several issues, including (1) the treatment of previously suspended losses that constitute QBI and (2) the determination of the Code Sec. 199A deduction for taxpayers that hold interests in regulated investment companies, charitable remainder trusts, and split-interest trusts. In Rev. Proc. 2019-11, the IRS provided guidance on the calculation of W-2 wages for purposes of Code Sec. 199A(b)(2), which limits the QBI deduction for some taxpayers whose taxable income exceeds a threshold amount ($160,700 for single filers; $321,400 for joint filers for 2019).

An issue of major concern for practitioners was determining whether a taxpayer's rental real estate activity qualified as a trade or business for purposes of the Code Sec. 199A deduction. The final regulations in T.D. 9847 set forth a list of nonexclusive factors to consider in determining whether rental real estate enterprises qualify for the Code Sec. 199A QBI deduction. The preamble to T.D. 9847 states that, in determining whether a rental real estate activity is a Code Sec. 162 trade or business, the relevant factors include, but are not limited to, (1) the type of rented property (commercial real property versus residential property), (2) the number of properties rented, (3) the owner's or the owner's agents day-to-day involvement, (4) the types and significance of any ancillary services provided under the lease, and (5) the terms of the lease (for example, a net lease versus a traditional lease and a short-term lease versus a long-term lease). But the IRS concluded in the preamble that a bright line rule on whether a rental real estate activity is a trade or business for purposes of Code Sec. 199A was beyond the scope of the final regulations.

Safe Harbor Provided for Rental Real Estate Activities. Recognizing the difficulties taxpayers faced in determining whether a taxpayer's rental real estate activity is sufficiently regular, continuous, and considerable for the activity to constitute a trade or business for purposes of the Code Sec. 199A deduction, the IRS issued Rev. Proc. 2019-38. Rev. Proc. 2019-38 provides a safe harbor under which a rental real estate enterprise may be treated as a trade or business. Under Rev. Proc. 2019-38, each rental real estate enterprise will be treated as a single trade or business if the taxpayer satisfies three requirements: (1) the taxpayer maintains of separate books and records to reflect income and expenses for each enterprise; (2) for enterprises in existence less than four years, the taxpayer performs at least 250 hours of services per year, and for enterprises in existence for at least four years, the taxpayer performs 250 hours of services per year in any three of the five previous years; and (3) the taxpayer maintains contemporaneous records documenting the services performed.

Further, Rev. Proc. 2019-38 provides that rental real estate services include, but are not limited to, (1) advertising to rent or lease the real estate; (2) negotiating and executing leases; (3) verifying information contained in prospective tenant applications; (4) collecting rent; (5) daily operation, maintenance, and repair of the property, including the purchase of materials and supplies; (6) management of the real estate; and (7) supervision of employees and independent contractors.

Mid-Year Sec. 199A Prop. Regs Provide Guidance for Cooperatives. In June, the IRS issued proposed regulations (REG-118425-18) which provide guidance to cooperatives and their patrons on calculating the Code Sec. 199A QBI deduction, as well as guidance to specified agricultural or horticultural cooperatives (specified cooperatives) and their patrons regarding the deduction for domestic production activities under Code Sec. 199A(g). The proposed regulations also (1) provide guidance on Code Sec. 199A(b)(7), relating to the rule requiring patrons of specified cooperatives to reduce their deduction for QBI under Code Sec. 199A(a); (2) provide a single definition of patronage and nonpatronage under Code Sec. 1388; and (3) remove the final regulations, and withdraw the proposed regulations that have not been finalized, under former Code Section 199. The IRS also issued a proposed revenue procedure in Notice 2019-27 that contains computational guidance for specified cooperatives on methods and appropriate sources of data, for calculating W-2 wages for purposes of Code Sec. 199A(g). Notice 2019-27 provided three methods for calculating W-2 wages for purposes of Code Sec. 199A(g)(1)(B)(i), which limits the amount of the deduction available to specified cooperatives to 50 percent of such cooperative's W-2 wages for the tax year.

Final Regs and Related Guidance Clarify Computations of 100 Percent Bonus Depreciation

Another important area where the IRS provided a significant amount of guidance to practitioners in 2019 was with respect to the additional first-year depreciation deduction (i.e., bonus depreciation) under Code Sec. 168(k). The TCJA increased the bonus depreciation deduction from 50 percent to 100 percent.

In September, the IRS issued final bonus depreciation regulations in T.D. 9874 along with proposed regulations in REG-106808-19. The final regulations reflect and clarify the increase of the bonus depreciation benefit and the expansion of the universe of qualifying property, particularly to certain classes of used property authorized by the TCJA. The final regulations contain rules regarding used property, substantially renovated property, and rules applicable to partnerships. The final regulations also address the date of acquisition of depreciable property, the computation of the bonus depreciation deduction, and the elections provided in Code Secs. 168(k)(5), 168(k)(7), and 168(k)(10). The proposed regulations addressed several issues including (1) certain property not eligible for bonus depreciation, (2) a de minimis use rule for determining whether a taxpayer previously used property; (3) components acquired after September 27, 2017, of larger property for which construction began before September 28, 2017; and (4) other aspects not dealt with in the previous proposed regulations.

The IRS also issued two important bonus depreciation safe harbor rules in 2019. In February, the IRS issued Rev. Proc. 2019-13 to provide a safe harbor method of accounting for determining bonus depreciation deductions for passenger automobiles that are subject to the luxury automobile depreciation limitations under Code Sec. 280F(a) (as amended by the TCJA). In general, the Code Sec. 179 and depreciation deductions for passenger automobiles are subject to dollar limitations for the year the taxpayer places the passenger automobile in service and for each succeeding year. For a passenger automobile that qualifies for the bonus depreciation deduction, the TCJA increased the first-year limitation amount by $8,000. If the depreciable basis of a passenger automobile for which bonus depreciation is allowable exceeds the first-year limitation, the excess amount is deductible in the first tax year after the end of the recovery period. The safe harbor method in Rev. Proc. 2019-13 allows depreciation deductions for the excess amount during the recovery period, subject to the depreciation limitations applicable to passenger automobiles. Thus, the safe harbor mitigates the anomalous result that occurs in the years after the placed-in-service year and before the first year succeeding the end of the recovery period.

In July the IRS issued Rev. Proc. 2019-33 to allow late elections or revocation of elections under Code Sec. 168(k)(5) (the election to deduct the cost of a specified plant in the year it was planted or grafted), Code Sec. 168(k)(7) (the election not to apply bonus depreciation), and Code Sec. 168(k)(10) (the election to deduct 50 percent, rather than 100 percent, of the cost of all qualified property) for property acquired by the taxpayer after September 27, 2017, and placed in service or planted or grafted during the taxpayer's tax year that includes September 28, 2017. The IRS explained that when it issued the proposed regulations under Code Sec. 168(k) in August of 2018 (which were later finalized in T.D. 9874), some taxpayers had already filed their tax returns or did not have sufficient time to analyze the proposed regulations before filing returns due in September or October of 2018.

IRS Acts to Prevent Taxpayers from Working Around the SALT Limitation

The $10,000 limit on deductions for state and local taxes (SALT) under Code Sec. 164(b)(6), as enacted by TCJA, was a major area of IRS activity in 2019.

In June, the IRS finalized regulations in T.D. 9864 providing that, in general, if a taxpayer makes a payment or transfers property to or for the use of an entity described in Code Sec. 170(c), and the taxpayer receives or expects to receive a state or local tax credit in return for such payment, the tax credit constitutes a return benefit to the taxpayer, or quid pro quo, reducing the taxpayer's charitable contribution deduction. Under the final regulations, a taxpayer must reduce its charitable contribution deduction if it receives or expects to receive state or local tax deductions in excess of the taxpayer's payment or the fair market value of property transferred by the taxpayer. However, under the final regulations, a taxpayer may disregard state and local tax credits as a return benefit where such credits do not exceed 15 percent of the taxpayer's payment.

The IRS also provided two important safe harbor rules to address issues that arose from the quid pro quo rule in the final regulations. Rev. Proc. 2019-12 allows C corporations and certain passthrough entities to treat payments to organizations described in Code Sec. 170(c) made in return for state or local tax credits to treat the payment as ordinary and necessary business expenses under Code Sec. 162(a) to the extent of the credit received. Notice 2019-12 provides a similar safe harbor for individuals who itemize deductions. Under Notice 2019-12, taxpayers who itemize deductions and make payments to a Code Sec. 170(c) organization in return for a state or local tax credit can treat as a payment of state or local tax the portion of the payment for which a charitable contribution deduction under Code Sec. 170 is disallowed under the final quid pro quo rule in the final regulations. Notice 2019-12 does not permit a taxpayer who applies this safe harbor to treat the amount of any payment as deductible under more than one provision of the Code or regulations. Notice 2019-12 also does not permit a taxpayer who applies the safe harbor to avoid the limitations of Code Sec. 164(b)(6) for any amount paid as a tax or treated under the notice as a payment of tax. In December, the IRS issued these two safe harbor rules in proposed regulations in REG-107431-19.

The interaction of the SALT deduction limit and state or local tax refunds was addressed in Rev. Rul. 2019-11. Under this ruling, if a taxpayer received a tax benefit from deducting state or local taxes in a prior year and the taxpayer recovers all or a portion of those taxes in the current year, the taxpayer must include in gross income the lesser of (1) the difference between the taxpayer's total itemized deductions taken in the prior year and the amount of itemized deductions the taxpayer would have taken in the prior year had the taxpayer paid the proper amount of state and local tax, or (2) the difference between the taxpayer's itemized deductions taken in the prior year and the standard deduction amount for the prior year, if the taxpayer was not precluded from taking the standard deduction in the prior year.

In PMTA 2019-1, the IRS Office of Chief Counsel addressed the interplay of the SALT limitation and the deduction for business use of a personal residence under Code Sec. 280A. The Office of Chief Counsel advised that, if a taxpayer's total individual state and local taxes meet or exceed the $10,000 limitation of Code Sec. 164(b)(6), or if the taxpayer chooses to take the standard deduction instead of itemizing deductions, none of the taxpayer's state and local taxes relating to the taxpayer's business use of the home are included as expenses under Code Sec. 280A(b). However, to the extent the excess of the taxpayer's state and local taxes that exceed $10,000 are attributable to the taxpayer's business, such expenses are deductible under Code Sec. 280A(c), subject to the gross income limitation under Code Sec. 280A(c)(5).

Certain Partnerships Allowed to File Superseding Forms 1065 and Schedules K-1

The Bipartisan Budget Act of 2015 (BBA) removed the TEFRA audit procedures from the Code and replaced them with the centralized partnership audit rules in Code Sec. 6221 through Code Sec. 6241. The new rules generally apply to all partnerships, but certain small partnerships are permitted to elect out of the centralized audit rules. The centralized partnership audit rules include Code Sec. 6031(b), which generally prohibits a partnership from amending its Schedules K-1 after the due date of its Form 1065.

In July, the IRS issued Rev. Proc. 2019-32 to provide an extension to partnerships that did not elect out of the centralized partnership audit regime (CPAR) to file amended Forms 1065 and furnish Schedules K-1. The extension applies only to partnership tax years that ended before the issuance of Rev. Proc. 2019-32 and for which the extended due date for the partnership tax year is after July 25, 2019. Partnership tax years beginning in 2018 were the first tax years for which the CPAR was mandatory and the first tax years for which restrictions on amended Schedules K-1 under Code Sec. 6031(b) were effective. Because some partnerships may have made errors on these initial returns, including not properly reporting all of the required information on the Schedules K-1, and due to the restrictions in Code Sec. 6031(b), these partnerships would not be able to amend their Schedules K-1. Thus, the IRS provided the relief in Rev. Proc. 2019-32 and said it will treat the timely filing of a Form 1065 by a partnership subject to the CPAR as a valid request for a six-month extension. Such a partnership is permitted to file a superseding Form 1065 and furnish corresponding Schedules K-1 before the expiration of the extended deadline.

Bipartisan Legislation Leads to Taxpayer First Act

In July, Congress passed, with bipartisan support, the Taxpayer First Act (P.L. 116-25) (TFA), which was aimed at (1) changing management and oversight of the IRS in order to improve customer service and the process for assisting taxpayers with appeals; (2) restricting certain IRS enforcement activities, including the use of private debt collectors in certain cases; and (3) modernizing the IRS's organization.

TFA amended Code Sec. 7803 to establish an IRS Independent Office of Appeals, which will be led by the Chief of Appeals, who will report to, and be appointed by, the IRS Commissioner. The IRS Independent Office of Appeals is tasked with resolving federal tax controversies, without litigation, on a basis which (1) is fair and impartial to both the government and the taxpayer; (2) promotes a consistent application and interpretation of, and voluntary compliance with, the federal tax laws, and (3) enhances public confidence in the integrity and efficiency of the IRS. The intent of the Independent Office of Appeals is to ensure that all taxpayers are able to access the administrative review process and have their cases heard by an independent decision maker and to provide for notice and protest procedures as well as additional Congressional oversight for taxpayers precluded from using the administrative review process. TFA contained other provisions intended to improve service to taxpayers, including a codification of the Free File program and a requirement that Free File program members continue to provide basic fillable forms to all taxpayers.

TFA increased penalties on tax return preparers and taxpayers who fail to file tax returns. TFA amended Code Sec. 6713 to increase the penalty for improper disclosure or use of information by tax return preparers. This penalty is imposed for the disclosure of taxpayer identity information by a return preparer in cases where such information is used in an identity theft crime, whether or not related to the filing of a tax return. TFA also increased the minimum penalty for failing to file a tax return to the lesser of $330 (up from $205) (indexed for inflation) or 100 percent of the amount required to be shown on the return, effective for returns required to be filed after December 31, 2019.

TFA expanded the use of electronic filing of returns by allowing the IRS to require individuals filing more than 10 returns (reduced from 250) to file them electronically. This requirement will be phased in between the years 2019 and 2021. In the case of a partnership, the applicable number is 200 in the case of calendar year 2018, 150 in the case of calendar year 2019, and 100 in the case of calendar year 2020. An exception to this requirement is provided for tax preparers located in geographic areas with limited or no internet access. TFA also extended the electronic filing requirement to all tax-exempt organizations required to file statements or returns in the Form 990 series or Form 8872, Political Organization Report of Contributions and Expenditures.

TFA changed the rules for the Tax Court's review of an innocent spouse determination by amending Code Sec. 6015 to clarify that the Tax Court has jurisdiction to redetermine equitable claims for relief from joint liability. TFA also specifies that the standard of review for such relief by the Tax Court must be conducted on a de novo basis, meaning that the Tax Court will take a fresh look at the case without taking previous decisions into account. The review will be based on the administrative record and any newly discovered or previously unavailable evidence. The provision also clarifies the time frame in which claims for equitable relief can be brought.

Prop. Regs Clarify Rules on Applicable Financial Statements; Allow Automatic Accounting Method Changes

TCJA amended Code Sec. 451(b) to provide that, for accrual method taxpayers, the "all events" test with respect to any item of gross income is not treated as met any later than when the item is included in revenue for financial accounting purposes on an applicable financial statement (AFS). In 2019, the IRS issued two sets of proposed regulations (REG-104870-18 and REG-104554-18) to provide guidance on the applicable of the AFS rule.

Prop. Reg. Sec. 1.451-3 explains the requirements of the AFS income inclusion rule in Code Sec. 451(b) and clarifies how the AFS income inclusion rule applies to accrual method taxpayers with an AFS. Under Prop. Reg. Sec. 1.451-3(b), the AFS income inclusion rule generally applies to accrual method taxpayers with an AFS when the timing of income inclusion for one or more items of income is determined using the all events test. Prop. Reg. Sec. 1.451-3(d)(1) clarifies that the AFS income inclusion rule applies only to taxpayers that have one or more AFS covering the entire tax year. Prop. Reg. Sec. 1.451-8 addresses the timing of income inclusion under Code Sec. 451 of advance payments for goods, services, and certain other items and provides a deferral method of accounting for taxpayers that do not have an AFS.

In addition, the IRS issued Rev. Proc. 2019-37, which provides additional automatic changes in method of accounting for a taxpayer to change its method of accounting in order to comply with Prop. Reg. Sec. 1.451-3 and Prop. Reg. 1.451-8. Rev. Proc. 2019-37 also provides an additional automatic method change for a taxpayer that changes the manner in which it recognizes amounts in revenue in an AFS and that wants to change its method of accounting.

Final Regs Prohibit Partners from Being Employees of a Disregarded Entity Owned by the Partnership

Generally, under Reg. Sec. 301.7701-2(c)(2)(i), a business entity that has a single owner and is not a corporation is disregarded as an entity separate from its owner (i.e., a disregarded entity). However, Reg. Sec. 301.7701-2(c)(2)(iv)(B) provides that a disregarded entity is treated as a corporation for purposes of employment taxes. Therefore, the disregarded entity, rather than the owner, is considered to be the employer of the entity's employees for employment tax purposes and is required to file the appropriate employment tax returns. While Reg. Sec. 301.7701-2(c)(2)(iv)(B) treats a disregarded entity as a corporation for employment tax purposes, this rule does not apply for self-employment tax purposes.

In 2016, the IRS issued a temporary regulation (T.D. 9766) clarifying the employment tax treatment of partners in a partnership that owns a disregarded entity. Before that, the regulations did not explicitly address situations in which the owner of a disregarded entity is a partnership, and the IRS noted that some taxpayers were reading the regulations to permit the partners to be treated (either directly or through tiered partnerships) as employees of the disregarded entity. Taxpayers found their way to this interpretation, the IRS said, because the regulations did not include a specific example applying the general rule in the partnership context. Under this reading of the rules, which the IRS stressed was not intended, partners were participating in certain tax-favored employee benefit plans to which they were otherwise not entitled to participate.

In July, the IRS finalized the temporary rules with the issuance of T.D. 9869. Reg. Sec. 301.7701-2(c)(2)(iv)(C)(2) clarifies that a disregarded entity that is treated as a corporation for purposes of employment taxes is not treated as a corporation for purposes of employing its individual owner, who is treated as a sole proprietor, or employing an individual who is a partner in a partnership that owns the disregarded entity. Rather, the entity is disregarded as an entity separate from its owner for this purpose. The IRS noted that existing regulations already provide that the entity is disregarded for self-employment tax purposes and specifically noted that the owner of an entity treated in the same manner as a sole proprietorship under Reg. Sec. 301.7701-2(a) is subject to tax on self-employment income. Accordingly, if a partnership is the owner of a disregarded entity, the partners in the partnership are subject to the same self-employment tax rules as partners in a partnership that does not own a disregarded entity.

IRS Loses in Court on Exempt Org Donor Reporting Changes; Issues Penalty Relief and Proposed Regs

Last year, the IRS issued Rev. Proc. 2018-38 to ease reporting requirements on certain exempt organizations. The procedure allowed organizations that are exempt from tax under Code Sec. 501(a), other than Code Sec. 501(c)(3) organizations, and that are required to file Form 990, Return of Organization Exempt From Income Tax, to omit the names and addresses of contributors of more than $5,000 on their Forms 990, 990-EZ, and 990-PP. The IRS said that the donor reporting requirement in Reg. Sec. 1.6033-2(a)(2)(ii)(f) increased compliance costs, consumed IRS resources, and posed a risk of inadvertent disclosure of the information.

A group of states including Montana challenged Rev. Proc. 2018-38 in a district court, arguing that the procedure exceeded the IRS's authority and that the change in the donor reporting rules should have been issued in proposed regulations in order to be subject to the notice-and-comment procedures. The states asserted that the change deprived them of previously available information and that they were now incurring expenses on their own.

In Bullock v. IRS, 2019 PTC 290 (D. Mont. 2019), the district court held that Rev. Proc. 2018-38 was an improper attempt by the IRS to amend a regulation. In the court's view, the procedure was a legislative rule that had to go through the notice and comment procedures. In response to the Bullock decision, the IRS issued Notice 2019-47 providing penalty relief to organizations that relied on Rev. Proc. 2018-38. The IRS also issued proposed regulations in REG-102508-16 that amend Reg. Sec. 1.6033-2(a)(2)(ii)(f) to specify that exempt organizations other than Code Sec. 501(c)(3) organizations are not required to report the names and addresses of contributors of more than $5,000 on their Forms 990, 990-EZ, and 990-PP.

Fifth Circuit Affirms ACA Individual Mandate Is Unconstitutional; But Severability Question Remains

In mid-December, in State of Texas v. U.S., 2019 PTC 481 (5th Cir. 2019), the Fifth Circuit affirmed a district court and held that (1) there remains a live case or controversy between Texas and other states opposed to the Patient Protection and Affordable Care Act (ACA) and the United States; (2) Texas and other states opposed to the ACA have standing to challenge the ACA because the individual mandate injures both the individuals in the states, by requiring them to buy insurance that they do not want, and the states, by increasing their costs of complying with the reporting requirements that accompany the individual mandate; and (3) the individual mandate is unconstitutional because it can no longer be read as a tax, and there is no other constitutional provision that justifies this exercise of congressional power.

However, on the question of how much, if any, of the rest of the ACA beyond the individual mandate is inseverable from the individual mandate, the Fifth Circuit remanded the case to the district court to provide additional analysis of the provisions of the ACA as they currently exist in light of the penalty for not having insurance being reduced to zero in the Tax Cuts and Jobs Act of 2017.

See related story in this issue of Parker's Federal Tax Bulletin.

Year-End Legislation Retroactively Extends Dozens of Tax Breaks and Makes Numerous Other Tax Changes

As a holiday gift to taxpayers, Congress included a number of individual and business friendly tax provisions in its year-end spending package, the Further Consolidated Appropriations Act, 2020 (the Act; Pub. L. 116-94). The Act brought back to life many deductions and credits that had expired at the end of 2017, as well as a few others that had either expired at the end of 2018 or were scheduled to expire at the end of 2019. In addition, the Act included:

(1) the repeal TCJA changes to the kiddie tax rules;

(2) new disaster relief tax provisions;

(3) the permanent repeal of the "Cadillac Tax" on high cost employer sponsored health insurance and two other healthcare taxes;

(4) the expansion of Section 529 plans; and

(5) major changes to retirement-related tax provisions.

For a special report on the Act, see the December 30, 2019 issue of Parker's Federal Tax Bulletin (PFTB 2019-12-30).

Observation: Unfortunately, one of the most notable aspects of the year-end spending package is its failure to include provisions fixing TCJA's notorious "retail glitch". Due to a drafting error in TCJA, the 15-year recovery periods that were available for qualified leasehold improvements, qualified restaurant property, and qualified retail improvement property placed in service before 2018, no longer exist for such property placed in service after 2017. Instead, the depreciation period is 39 years. Thus, until legislation is enacted fixing this mistake, such property does not meet the bonus depreciation criteria specified in Code Sec. 168(k)(2)(A) (i.e., the recovery period is not 20 years or less) and is thus not eligible for bonus depreciation.

Disclaimer: This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their particular situations. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer. The information contained herein is general in nature and based on authorities that are subject to change. Parker Tax Publishing guarantees neither the accuracy nor completeness of any information and is not responsible for any errors or omissions, or for results obtained by others as a result of reliance upon such information. Parker Tax Publishing assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect information contained herein.

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