Are Monies Received From a Court Judgment Taxable?

They could be.  The Tax Court ruled in favor of the IRS requiring the taxpayer to include in taxable income (1) Proceeds the taxpayer received plus (2) The amount awarded to the attorney.   The court also upheld IRS's imposition of an accuracy-related penalty. Raphael Dang-Quang Cung, TC Memo 2013-81

CHARITABLE AWAY-FROM-HOME TRAVEL

 Charitable deductions are allowed only for travel expenses (including meals and lodging) by volunteers who do charitable work for their organization while they are away from home on the charity's behalf. Unlike other areas of taxes, meals are not subject to the 50% limitation. Any “significant element of personal pleasure” negates a complete deduction (i.e., not even a partial deduction is allowed). Significant personal pleasure is assumed if the taxpayer has only minor duties and is not required to perform any duties for the charity for major portions of the away-from-home stay. If the taxpayer's personal vehicle is used for the charitable travel, then the taxpayer may deduct the cost of gas and oil, but not depreciation, insurance, or repairs. As an alternative to deducting the cost of gas and oil, the taxpayer can use the current standard mileage rate of 14 cents per mile for charitable travel. The taxpayer can also deduct parking fees and tolls, whether actual expenses or the standard mileage rate is used.

The 14 cents per mile is not adjusted for inflation, so the current high cost of gasoline may well make it appropriate to document the cost of gas and oil for charitable trips. For example, when this article was prepared, gasoline prices were in the range of $4.50 per gallon in many parts of the country. Assuming that a vehicle gets 20 miles to the gallon, this turns out to be 22.5 cents per mile just for the cost of gasoline. Where there is significant charitable usage, it may be worth the time to document the gasoline usage for the year.

Car expenses record requirements - If you claim expenses claimed directly relate to the use of the taxpayers car in giving services to a qualified organization, reliable written records must be kept of the expenses. Whether the records are considered reliable depends on all of the facts and circumstances. Generally, they may be considered reliable if the taxpayer made them regularly and at or near the time in which the expenses were incurred.

For example, the records might show the name of the organization the taxpayer was serving, as well as the dates the car was used for a charitable purpose. If the standard mileage rate of 14 cents per mile was used, the records must show the number of miles that the taxpayer drove the car specifically for the charitable purpose. If actual expenses are deducted, the records must show the costs of operating the car that are directly related to a charitable purpose.

If you have questions related to the deductibility of your charity volunteer expenses, please give this office a call.

 2013 WILL HIT HIGHER-INCOME TAXPAYERS HARD

Now that Congress has passed the American Taxpayer Relief Act of 2012 (ATRA) and avoided the so-called “fiscal cliff,” higher-income taxpayers need to brace for higher taxes. There are numerous provisions in the ATRA that don’t provide the higher-income taxpayer any relief, and when these are combined with the provisions of the 2010 Affordable Health Care Act, higher-income taxpayers will feel a significant increase in taxes for which they need to prepare.

Virtually all of the increases are based on a taxpayer’s filing status and income, and even individuals who don’t perceive themselves as higher-income taxpayers may be surprised if they have a substantial gain from the sale of stocks, sale of a home or rental, sale of a business, the exercise of stock options, and just about any other event that would inflate income for the year or generate investment income.

So here are the things to watch for in 2013:

·  Personal Exemption Phase-out – For tax years beginning after 2012, ATRA reinstated the Personal Exemption Phase-out (PEP), which had been suspended in 2010 through 2012. It is interesting to note that the reinstated phase-out thresholds are higher than in previous years, thus requiring significantly higher income before the phase-out begins to take effect. The otherwise allowable exemption amounts are reduced by 2% for each $2,500, or part of $2,500 ($1,250 for married filing separately), that the taxpayer's AGI exceeds the amount shown in the table below for the taxpayer's filing status.

Example: Ralph and Louise have an AGI of $412,500 for 2013 and two children for a total of four exemptions totaling $15,600 (4 x $3,900). The threshold for a married couple is $300,000; thus, their income exceeds the threshold by $112,500. Dividing $112,500 by $2,500 equals 45. So 90% (45 x 2%) of their $15,600 exemption allowance is phased out, leaving them with a reduced exemption deduction of $1,560 ((100-90) x $15,600). Assuming Ralph and Louise are in the 33% federal tax bracket, the phase-out costs them an additional $4,633 ($15,600 x 90% x 33%).
Planning Tips – Taxpayers subject to the phase-out should consider relinquishing the exemption of a dependent child to the other parent, in cases where the parents are divorced or separated. Where a taxpayer is party to a multiple support agreement, the taxpayer may want to allow another contributing member of the agreement who is not hit by the phase-out to claim the dependent’s exemption.

 

·  Itemized Deduction Phase-out – The itemized deduction phase-out referred to as the “Pease” limitation, which, like the personal exemption phase-out, had been suspended for 2010 through 2012, is reinstated for 2013 and later years. The AGI threshold amounts are the same as the exemption thresholds shown in the table above. Like the exemption phase-out thresholds, the reinstated itemized deduction phase-out thresholds are higher than they were in earlier years, thus requiring significantly higher income before the phase-out begins to take effect. For taxpayers subject to the “Pease” limitation, the total amount of their itemized deductions is reduced by 3% of the amount by which the taxpayer's adjusted gross income (AGI) exceeds the threshold amount, with the reduction not to exceed 80% of the otherwise allowable itemized deductions.

Not all itemized deductions are subject to phase-out. The following deductions are not subject to the phase-out:

o Medical and dental expenses

o Investment interest expense

o Casualty and theft losses from personal use property

o Casualty and theft losses from income-producing propert 

o Gambling losses

Thus, a taxpayer who is subject to the full phase-out still gets to deduct 20% of the deductions subject to the phase-out and 100% of the deductions listed above.

Example: Ralph and Louise from the previous example, who had an AGI of $412,500 for 2013, exceed the threshold for a married couple by $112,500. Thus, they must reduce their itemized deductions subject to the phase-out by $3,375 (3% of $112,500) but not exceeding 80% of the deductions subject to the phase-out. For 2013, Ralph and Louise had the following itemized deductions:

The phase-out is the lesser of $3,375 or 80% of $24,000. Thus Ralph and Louise’s itemized deductions for 2013 will be $32,625 ($24,000 - $3,375 + $12,000). Assuming Ralph and Louise are in the 33% federal tax bracket, the phase-out will cost them an additional $1,114 ($3,375 x 33%)

Planning Tip – Conventional thinking is to maximize deductions. However, where taxpayers are not normally subject to phase-out and have a high-income year because of unusual income, it may be appropriate, where possible, to defer paying deductible expenses to the year following the high-income year, or perhaps pay and deduct the expenses in the preceding year.

·  Ordinary Income Tax Rate Increase – Beginning in 2013, the ATRA retained the graduated tax marginal rates that are adjusted annually for inflation, and added a new top rate of 39.6% (previously the top rate was 35%). Thus, higher-income taxpayers who fall within this new bracket will be subject to an additional 4.6% tax on their income above the threshold for this new bracket. The thresholds are:

o $450,000 for joint filers and surviving spouses;

o $425,000 for heads of household;

o $400,000 for single filers; and

o $225,000 for married filing separately.

Example: Jack and Sally who are filing jointly have an ordinary taxable income of $600,000. Their income above $450,000 will be subject to the 39.6% tax rate. Thus, they will see a tax increase of $6,900 (($600,000 - $450,000) x 4.6%) as a result of the new tax bracket.

·  Capital Gains and Dividends – Beginning in 2013, ATRA permanently increased the top rate for long-term capital gains and qualified dividends to 20% (up from 15%) for taxpayers with incomes exceeding the following for 2013 (inflation adjusted for future years):

o $450,000 for joint filers and surviving spouses;

o $425,000 for heads of household;

o $400,000 for single filers; and

o $225,000 for married filing separately.

This results in an increase of 5% (20% – 15%) in capital gains rates for higher-income taxpayers.

Example: Howard, a single individual, retired this year and sold his rental, which he had owned for a long time, for a profit of $700,000. Even though his income is generally in a lower-income tax bracket, the profit from the sale itself pushed his income above the $400,000 threshold for single taxpayers, and to the extent his income exceeds the $400,000 threshold, he will be subject to the increased capital gains rate. Had Howard’s other taxable income been $50,000, then he would have had a total income of $750,000, of which $350,000 exceeds the 20% long-term CG rate threshold. As a result, Howard pays the 20% rate on $350,000. That is an increase of $17,500 ($350,000 x 5%) over what he would have paid in 2012.

Caution – Generally, sales that are subject to long-term capital gains rates are also investment income subject to the 3.8% unearned income Medicare contribution tax that is part of the Affordable Care Act discussed later in this article.

Planning Tip – If Howard had utilized an installment sale, he could have spread the gain over multiple years and possibly avoided the higher CG rate. He might have also utilized a tax-deferred exchange to defer the gain into other real estate property.

·  Increased Hospital Insurance Tax – As part of the Affordable Health Care Act, beginning in 2013, the Hospital Insurance (HI) tax rate (currently at 1.45%) will be increased by 0.9% on individual taxpayer earnings (wages and self-employment income) in excess of compensation thresholds for the taxpayer's filing status. Married taxpayers must combine their incomes subject to HI tax when computing this additional tax. Thus, for wages the HI tax rate will be 1.45% up to the income threshold and 2.35% (1.45 + 0.9) on amounts in excess of the income threshold. The hospital insurance portion of the self-employed tax rate will be 2.9% up to the income threshold and 3.8% (2.9 + 0.9) on amounts in excess of the threshold. The income thresholds where this increase begins are $250,000 for married taxpayers filing jointly, $125,000 for married taxpayers filing separately, and $200,000 for all other taxpayers.

Employers are required to withhold the additional tax once wages exceed $200,000, but only on income from that employer. Employers cannot adjust the HI withholding based upon the employee having additional employment or a spouse who also works. Thus, there will be situations where the taxpayers will be under-withheld for the year.

Example – Jack and Jill are both employed. Jack’s wages are $175,000, and Jill’s wages are $150,000. Since neither employee’s wages exceed $200,000, their employers do not withhold the additional 0.9% for HI tax on either Jack’s or Jill’s wages. When they file their joint 1040 return, they will need to include $675 (($175,000 + $150,000 - $250,000) x 0.009) HI tax as part of their total tax. Jack and Jill may need to adjust their income tax withholding or make estimated tax payments to account for the extra HI tax and to avoid any underpayment penalty.

·  Unearned Income Medicare Contribution Tax – As part of the Affordable Health Care Act, a new tax takes effect beginning in 2013. The official name of this tax is the “Unearned Income Medicare Contribution Tax,” and even though the name implies it is a contribution, don’t get the idea you deduct it as a charitable contribution. It is, in actuality, a surtax levied on the net investment income of higher-income taxpayers.

The surtax is 3.8% on the lesser of your net investment income or the excess of your modified adjusted gross income (MAGI) over a threshold based on your filing status. MAGI is your regular AGI increased by income excluded for working out of the country; net investment income is your investment income reduced by investment expenses.

The filing status threshold amounts are:

o $250,000 for married taxpayers filing jointly and surviving spouses.

o $125,000 for married taxpayers filing separately.

o $200,000 for single and head of household filers.

Example - A single taxpayer has net investment income of $100,000 and MAGI of $220,000. The taxpayer would pay a Medicare contribution tax only on the $20,000 amount by which his MAGI exceeds his threshold amount of $200,000, because that is less than his net investment income of $100,000. Thus, the taxpayer's Medicare contribution tax would be $760 ($20,000 × 3.8%).

Investment income includes:

o Interest, dividends, annuities (but not distributions from IRAs or qualified retirement plans), and royalties,

o Rents (other than derived from a trade or business),

o Capital gains (other than derived from a trade or business),

o Home sale gain in excess of the allowable home gain exclusion,

o A child’s investment income in excess of the excludable threshold if, when eligible, the parent elects to include his or her child’s investment income on the parent’s return,

o Trade or business income that is a Sec. 469 passive activity with respect to the taxpayer, and

o Trade or business income with respect to trading financial instruments or commodities.

Planning Tips: For surtax purposes, gross income doesn't include interest on tax-exempt bonds. Thus, one can avoid the net investment income surtax by investing in tax-exempt bonds. A taxpayer can also utilize the installment sale provisions to spread gains from capital assets such as rentals and business assets over a number of years to keep the investment income under the tax threshold.

Investment expenses include:

o Investment interest expense,

o Investment advisory and brokerage fees,

o Expenses related to rental and royalty income, and

o State and local income taxes properly allocable to items included in Net Investment Income. 

Do you think you will never get hit with this tax because your income is way under the threshold amounts? Don’t be so sure. When you sell your home, the gain is a capital gain, and to the extent that the gain is not excludable using the home gain exclusion, it will add to your income and possibly push you above the taxation thresholds. And, since capital gains are investment income, you might be in for a surprise. The same holds true for gains from selling stock and a second home. So when planning to sell a capital asset, be sure to consider the impact of this new surtax.

The surtax also applies to undistributed net investment income of trusts and estates, and there are special rules applying to the sale of partnership and Sub-S Corporation interests. .

If you are subject to these new and increased taxes on higher-income taxpayers, it may be appropriate to review your situation so that you can avoid any unpleasant tax surprises at the end of 2013 and to adjust your withholding and estimated taxes if necessary to prevent underpayment penalties. Please give this office a call for assistance.

What to Do If You Are Missing a W-2

 

Have you received all of your W-2s? These documents are essential for completing individual tax returns. You should receive a Form W-2, Wage and Tax Statement, from all of your employers each year. Employers have until January 31st to provide or send you a 2012 W-2 earnings statement, either electronically or in paper form. If you have not received your W-2, follow these steps:

 

Contact Your Tax Preparer - And let him or her know that you are missing a W-2. If your appointment is in the near future, your preparer will advise you whether to keep the appointment or change it to another time. Generally, when a W-2 or 1099 is missing, it is best to keep the appointment so that everything else for the return can be completed. You can then mail the missing document to the office or drop it off at a later date. That way, your return can be finished as soon as the W-2 or 1099 is available, which will speed up your refund, if you are receiving one.

1. Contact Your Employer - Contact your employer to inquire if and when the W-2 was mailed. If it was mailed, it may have been returned to the employer due to an incorrect or incomplete address. After contacting the employer, allow a reasonable amount of time for the employer to resend or re-issue the W-2.
2. Contact the IRS - If you still have not received your W-2 by February 15, you can contact the IRS for assistance at 800-829-1040. However, we recommend that you hold off from contacting the IRS until you are certain that you will not be receiving a W-2 from the employer. If and when you do call the IRS, have the following information at hand:
• Employer's name, address, city, and state, including zip code;
• Your name, address, city, state, zip code, and Social Security number; and
• An estimate of the wages you earned, the federal income tax withheld, and the period in which you worked for that employer. The estimate should be based on year-to-date information from your final pay stub or leave-and-earnings statement, if possible. This office can assist you with making the estimate.
3. File Your Return - Even if you don’t receive a W-2, you are still required to file your tax return or to request a filing extension by April 15.
• If you anticipate that you will ultimately receive the missing W-2, this office can estimate your 2012 tax liability and file extensions for you. If you have a substantial refund coming, you may opt to have this office prepare a substitute W-2, enabling you to file without the W-2. Refunds for returns, including substitute W-2s, can be delayed significantly while the IRS verifies the W-2 information.
• If you don’t anticipate receiving the missing W-2, then this office can prepare a substitute W-2, enabling you to file your 2012 tax return.

If a substitute W-2 is used and it is later determined that the information used to prepare the substitute W-2 was in error, an amended return may need to be prepared for you to be able to file.

Please call this office if you have questions or need assistance.

Splitting Inherited IRAs before Year's End

If you or others were the beneficiaries of an inherited IRA whose owner died in 2011, December 31, 2012 is an important deadline.

Tax law requires a non-spouse beneficiary of an inherited IRA who wishes to spread distributions from the IRA over his or her lifetime to begin taking distributions from an inherited IRA account by the end of the year after the year of the IRA owner's death. These distributions are based upon the life expectancy of the beneficiary and are called required minimum distributions (RMDs).

Example - Leslie is the beneficiary of her father's IRA account. Her father, Thomas, passed away in 2011. If Leslie wishes to defer taking distributions from her inherited IRA over her remaining lifetime, she must begin taking RMDs by December 31, 2012.

However, where there are multiple beneficiaries, the life expectancy used to determine the RMDs from the IRA is based upon the age of the oldest beneficiary. Thus, younger beneficiaries would be required to take their RMDs over a shorter period of time than their life expectancy would otherwise require.

Example - Assume that Leslie, from our previous example, whose life expectancy is 32.3 years using the single life table that the IRS provides, has a younger brother, Robert, who is a co-beneficiary of their father's IRA account. Based on his age, and from the single life table, Robert's life expectancy is 42.7 years. However, Robert must use the shorter distribution period of his older sister because the distributions are from their father's IRA account and the RMDs must be based on Leslie's life expectancy of 32.3 years.

This oldest beneficiary rule can be overcome by splitting the inherited IRA into multiple IRA accounts, equally divided among the beneficiaries, before December 31 of the year following the year of the IRA owner's death. Where an IRA is divided into separate accounts (i.e., subaccounts), the RMD rules separately apply to each separate account, effective for years after the year in which the separate accounts were created or the IRA owner's date of death, if later.

Example - If Leslie and Robert, from our prior example, split the IRA into separate accounts prior to December 31, 2012, each can base his or her RMDs on his or her own life expectancy (32.3 years for Leslie and 42.7 years for Robert) and once the accounts are split, make his or her own investment decisions.

Additionally, a separate accounting must allocate all post-death investment gains and losses for the period before the separate accounts were established on a pro rata basis in a reasonable and consistent manner among the separate accounts. However, once the separate accounts are actually established, each beneficiary can make his or her own investment decisions from that point on.

If you have questions related to this RMD requirement, please give this office a call.

Year-End Tax Planning Moves for Businesses

As the end of the year approaches, many are looking for ways to reduce their business profits before year's end. Here are some possible moves that might apply to your situation.

Self-employed Retirement Plans - If you are self-employed and haven't done so yet, you may wish to establish a self-employed retirement plan. Certain types of plans must be established before the end of the year to make you eligible to deduct contributions made to the plan for 2012, even if the contributions aren't made until 2013. You may also qualify for the pension start-up credit.

Increase Basis - If you own an interest in a partnership or S corporation that is going to show a loss in 2012, you may need to increase your basis in the entity so you can deduct the loss, which is limited to your basis in the entity.

Hire Veterans - If you are considering hiring some new employees between now and the end of the year, you might consider hiring a qualifying veteran so that you can qualify for the work opportunity tax credit (WOTC). The WOTC for hiring veterans in 2012 ranges from $2,400 to $9,600, depending on a variety of factors (such as the veteran's period of unemployment and whether he or she has a service-connected disability).

Purchase Equipment - If you are in the market for new business equipment and machinery and you place them in service before year-end, you will qualify for the 50% bonus first-year depreciation allowance. Or, you can elect to expense up to $139,000 of the newly acquired items using the Sec 179 expensing allowance. The $139,000 expense limit is reduced by one dollar for every dollar in excess of the $560,000 annual investment limit.

Purchase an SUV for Business - If you are in the market for a business car, and your taste runs to large, heavy SUVs (those built on a truck chassis and rated at more than 6,000 pounds gross [loaded] vehicle weight), consider buying in 2012. Due to a combination of favorable depreciation and expensing rules, and depending on the percentage of business use, you may be able to write off most of the cost of the heavy SUV this year.

These are just some of the year-end steps that can be taken to save taxes. Please contact this office so we can tailor a plan to your particular needs.

Will Capital Gains Be Changed?

Currently, capital gains rates for the sale of assets held over one year are taxed at 15% (0% to the extent a taxpayer is in the 15% or lower regular tax bracket), compared with a top tax of 35% for ordinary income. Without Congressional action, these rates will increase to 20% (18% for assets held over 5 years) in 2013.

Although there has been some discussion related to extending the 15% rates for another year (2013), to date, Congress has not provided any indication one way or the other. Even without providing guidance for 2013, the House Ways and Means Committee and the Senate Finance Committee are already holding joint meetings to discuss capital gain reform.

Capital gains and related issues make up approximately half of the tax code, in excess of 20,000 pages. In addition, those with the most capital gains are generally the wealthier taxpayers, and lower capital gains rates contribute to the disparity in tax rates between the wealthy and the average working family that we hear so much about in the media. As an example, Billionaire Warren Buffet announced that his tax rate was 14%, which is lower than the rate paid by his secretary.

Some contend that capital gains should be taxed as ordinary income and should even be taxed as the income is earned rather than when the gain is realized.

Still others maintain that doing away with special long-term capital gains rates would discourage investment and would further harm the economy.

It is difficult to predict what lies ahead. But you can count on this firm to stay on top of this issue and to keep you abreast of the ever-changing tax landscape.

CONGRESS LEAVES US HANGING AGAIN ON THE AMT

Here it is, almost the end of the year, and as they have done for several years, Congress has not indicated if they will extend the higher AMT exemption amounts or allow them to revert to lower amounts that were in effect before exemptions were increased to shield the middle class from the punitive tax. A recent Congressional report indicates that, if Congress does not extend the AMT break, one in five taxpayers will be impacted by the AMT in 2012.

Originally conceived to combat taxpayers in the higher-income brackets who utilized legal tax shelters and tax preferences to avoid paying income tax, the AMT can be tricky and hit you when least expected. The tax was supposed to inflict a “minimum” tax on those who were able to avoid the regular tax. However, years of inflation have pushed many middle-income taxpayers into the reach of the AMT. Although there is a long list of items that can trigger the AMT, for most individuals, the triggers include the following or a combination of the items listed below:

·      Preference income from exercising stock options from an employer's qualified plan, sometimes referred to as incentive stock options (ISOs);

·      Having large itemized tax deductions;

·      Having large miscellaneous itemized deductions;

·      Large itemized deductions for state income or sales tax, real property tax and personal property tax;

·      Large medical itemized tax deductions;

·      Home equity debt interest deduction; and

·      Interest income from private activity bonds.

Because of its unintended impact on the middle class, Congress has been promising AMT reform. In the meantime, annually increasing the amount of income exempted from AMT has been their temporary fix, and what that amount will be for 2012 is what Congress has yet to decide. Complicating the issue is that the AMT as it is currently structured provides a significant amount of tax revenue that Congress is reluctant to concede without a replacement. Most analysts have been predicting the higher exemptions will be extended for 2012, and possibly into 2013. But you never know, and we will have to wait and see.

There are planning techniques that can be used to avoid or mitigate the effects of the AMT. If you anticipate an AMT problem this year, it may be appropriate for you to make an appointment to see if there are any steps that can be taken to alleviate the effects of the AMT in your specific tax situation.

Arrangements that Recharacterize Taxable Wages as Nontaxable Reimbursements or Allowances

The IRS has provided guidance which clarifies that an arrangement that recharacterizes taxable wages as nontaxable reimbursements or allowances does not satisfy the business connection requirement for accountable expense reimbursement plans.

In general, employee business expense reimbursements that are paid through an employer's accountable expense reimbursement plan are excluded from the employee's adjusted gross income. An accountable plan basically requires employees to submit receipts for expenses and repay any advances that exceed substantiated expenses. Amounts paid to employees through an accountable plan are not taxable compensation. Thus, they are not subject to federal or state income taxes or Social Security taxes, or employer payroll taxes and withholding.

On the other hand, business expense reimbursements paid through a system that does not meet the specific requirements for accountable plans are considered paid under a nonaccountable plan, and are treated as taxable compensation. An employer can have a reimbursement plan that is considered accountable in part and nonaccountable in part.

A reimbursement plan must meet three requirements in order to be considered an accountable expense allowance arrangement

(1)  Reimbursements must have a business connection;

(2)  Reimbursements must be substantiated; and

(3)  Employees must return reimbursements in excess of expenses incurred.

An arrangement satisfies the business connection requirement if it provides advances, allowances, or reimbursements only for business expenses that are allowable as deductions, and that are paid or incurred by the employee in connection with the performance of services as an employee of the employer. Therefore, not only must an employee actually pay or incur a deductible business expense, but the expense must arise in connection with the employment for that employer.

The business connection requirement will not be satisfied if a payer pays an amount to an employee regardless of whether the employee incurs or is reasonably expected to incur deductible business expenses. Failure to meet this reimbursement requirement of business connection is referred to as wage recharacterization because the amount being paid is not an expense reimbursement but rather a substitute for an amount that would otherwise be paid as wages.

The IRS guidance includes four situations, three of which illustrate arrangements that impermissibly recharacterize wages such that the arrangements are not accountable plans. A fourth situation illustrates an arrangement that does not impermissibly recharacterize wages. In this arrangement, an employer prospectively altered its compensation structure to include a reimbursement arrangement.

Because of the difference in tax treatment of reimbursements under an accountable plan versus a nonaccountable plan, it is important to review your reimbursement policies. Please call our office for an appointment to discuss your options under this IRS guidance.