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100% deduction for trucker per diem in COVID-19 Pandemic Relief Package confirmed by the IRS in Notice 2021-63 (12/6/2021)

[Update: The temporary 100% deduction for per diem expired on December 31, 2022]


Full Deduction for Business Meals

Congress used a single line on page 4871 of the Consolidated Appropriations Act, 2021 (CAA) to allow the full deduction for per diem. Section 210 of the act temporarily raised the allowance of business meals (for food or beverages provided by a restaurant) under IRC § 274(n) to 100% from 50% for tax years 2021 and 2022.

The IRS issued Notice 2021-25 on April 8, 2021 (updated by Notice 2021-63 on December 6, 2021) that explains when the temporary 100-percent deduction applies and when the 50-percent limitation continues to apply for purposes of § 274 of the Internal Revenue Code (Code), as amended by § 210 of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Act), enacted as Division EE of the Consolidated Appropriations Act, 2021, Pub. L. No. 116- 260, 134 Stat. 1182 (December 27, 2020)

The IRS previously allowed motor carriers and self-employed truckers using the Special Transportation Industry per diem to deduct business meals at 80% under 274(n)(3). Unfortunately, Congress omitted any commentary on the interplay of 274(n)(1) and (3) in the CAA. On April 9, 2021, I called the Office of Associate Chief Counsel (Income Tax & Accounting) and obtained confirmation the temporary 100-percent deduction for business meal expenses applied to the transportation industry as well. The Associate Chief Counsel's opinion was affirmed by issuance of IRS Notice 2021-63 on December 6, 2021.

"Absolutely yes, we tried to allow as many taxpayers to use it as possible"

Deena Devereux, IRS Office of Associate Chief Counsel

Introducing Per Diem Plus Small Fleets, an affordable, customizable per diem solution for solo and team operators

Internal Revenue Code Section 274

26 U.S. Code § 274 - Disallowance of certain entertainment, etc., has been revised as follows (as modified by the CAA):

(n) 100 percent of meal expenses allowed as deduction

(1) In general:

The amount allowable as a deduction under this chapter for any expense for food or beverages shall not exceed 100 percent of the amount of such expense which would (but for this paragraph) be allowable as a deduction under this chapter.

(2) Exceptions

Paragraph (1) shall not apply to any expense if—

(A) such expense is described in paragraph (2), (3), (4), (7), (8), or (9) of subsection (e),

(B) in the case of an employer who pays or reimburses moving expenses of an employee, such expenses are includible in the income of the employee under section 82, or

(C) such expense is for food or beverages— (i) required by any Federal law to be provided to crew members of a commercial vessel,(ii) provided to crew members of a commercial vessel.

(D) such expense is—
(i) for food or beverages provided by a restaurant, and
(ii) paid or incurred before January 1, 2023.

(3) Special rule for individuals subject to Federal hours of service (superseded by CAA)

In the case of any expenses for food or beverages consumed while away from home (within the meaning of section 162(a)(2)) by an individual during, or incident to, the period of duty subject to the hours of service limitations of the Department of Transportation, paragraph (1) shall be applied by substituting “80 percent” for “50 percent”


Examples

Motor Carrier: A motor carrier with an effective Federal tax rate of 10% paying trucker per diem to a driver who is away from home an average 280 nights per year will save with the full deduction for per diem an additional $370 per year in 2021 and 2022.

  • Fleet per diem savings per driver 2020: $2,694
  • Fleet per diem savings per driver 2021 & 2022: $3,064

Owner Operator: An independent owner operator operating one-truck with an effective Federal tax rate of 18% claiming trucker per diem and averaging 280 nights away from home per year will save with the full deduction for per dieman additional $665 per year in 2021 and 2022.

  • Owner operator savings 2020: $2,393
  • Owner operator savings 2021 & 2022: $3,064


Use our Fleet Per Diem Benefit Calculator to learn how much your fleet can save with Per Diem Plus Fleets


Per Diem Plus FLEETS is a configurable mobile application enterprise platform that automates administration of an IRS-compliant accountable per diem plan for truck drivers and fleets managers. No matter how big or small your company is, Per Diem Plus has a solution for you.

About Per Diem Plus

The Per Diem Plus® is the only IRS-compliant mobile application that provides automatic trucker per diem and travel-related expense tracking for drivers, motor carriers and owner operators. Per Diem Plus was designed, developed and is managed in the USA.


About the Author

Mark is tax counsel for Per Diem Plus. With nearly two decades of experience advising trucking companies on per diem issues, Mark was responsible for defining the Per Diem Plus software logic rules that automatically calculates trucker per diem in accordance with IRS regulations. He also previously served as the consulting per diem tax expert for Omnitracs.

In addition to his time working with Per Diem Plus, Mark works in private practice as an Enrolled Agent at Mark Sullivan Consulting, PLLC specializing in federal tax controversy representation and consulting. He also served as the consulting and expert witness for the Federal Defenders Office and private defense counsel in financial crimes cases in multiple federal district courts. Contact Mark W. Sullivan, EA


Copyright 2021, 2022, 2023 Per Diem Plus, LLC. Per Diem Plus proprietary software is the trademark of Per Diem Plus, LLC.®

Disclaimer: This article is for information purposes only and cannot be cited as precedent or relied upon in a tax dispute before the IRS.

The Impact of the Biden Administration’s Tax Proposals by State and Congressional District

2021 TAX LAW UPDATE - READ ABOUT 100% DEDUCTION FOR PER DIEM

How much will your taxes increase?

The Biden administration has proposed $2.3 trillion in new taxes in its 2022 budget essentially undoing the significant tax cuts implemented by the 2017 Tax Cuts and Jobs Act. Under Biden's proposal taxes will increase for the 40% of taxpayers that paid income taxes in 2020 in roughly 96% of congressional districts. Residents of the District of Columbia, Massachusetts, Connecticut and New York will experience the largest average tax increases - $1,000 in 2022 alone. Taxpayers with kids living in Mississippi, Alabama, and Oklahoma should expect a tax cut of over $400 in 2022. However, by 2025 (after the next Presidential election) taxpaying residents of every state and the District of Columbia will see a tax increase.

Whether or not your taxes will increase depends on several factors 1) income source, self-employed or W-2 employee 2) the number of qualifying children you have, and 3) the state and congressional district you reside. Click HERE to to use the Tax Foundation interactive map to project tax changes by your state and district.



Phoenix vs. Nogales: An illustration of income redistribution

Arizona taxpayers residing in District 6 (Phoenix) on average earn $126,760 and can expect their taxes to increase $2,247.77. For comparison District 3 (Nogales) residents on average earn only $50,131 and will receive a significant tax cut of $1,407. In fact, the largest tax cuts on average per filer are in majority-Hispanic districts in California, Texas, and Arizona, with tax cuts exceeding $1,500 per filer in 2022. However, this is not a result of carve-out legislation but primarily to the expanded Child Tax Credit, Hispanic population density and predominance of the nuclear, Roman Catholic family in Hispanic culture.1



The 2017 TCJA cut taxes for the majority of Americans. Unfortunately, President Biden believes the 40% of Americans that paid income taxes in 2020 are not paying enough and has proposed $2.3 trillion in new taxes. Whether your income taxes will increase can be projected based your state of residence and congressional district.


About Per Diem Plus

The Per Diem Plus® is the only IRS-compliant mobile application that provides automatic trucker per diem and travel-related expense tracking for drivers, motor carriers and owner operators. Per Diem Plus was designed, developed and is managed in the USA.


This article was written by Mark W. Sullivan EA, Tax Counsel for Per Diem Plus, who has over a decade of experience advising trucking companies on per diem issues. Prior to starting a private practice in 1998, Mr. Sullivan was an Internal Revenue Officer with the New York, NY, Saint Louis, MO and Washington, D.C. offices of the Internal Revenue Service.  Questions? Contact Mark W. Sullivan, EA.

Copyright 2021 Per Diem Plus, LLC. Per Diem Plus proprietary software is the trademark of Per Diem Plus, LLC.®

Disclaimer: This article is for information purposes only and cannot be cited as precedent or relied upon in a tax dispute before the IRS.


2021 TAX LAW UPDATE - READ ABOUT 100% DEDUCTION FOR PER DIEM

Does your state tax forgiven PPP loans?

Did you receive a Paycheck Protection Program Loan (PPP) in 2020 to keep your small trucking company from going under? Did you use the loan proceeds for qualifying purposes, like payroll costs, mortgage interest payments, rent, and utilities? The good news is your loan should be forgiven AND it will be exempt from federal taxation. The bad news is that many states do not conform to the federal tax code and will tax them by either treating forgiven loans as taxable income, denying the deduction for expenses paid for using forgiven loans, or both. The Tax Foundation map below and (click HERE to view state-by-state table show states’ tax treatment of forgiven PPP loans.


Fortunately several states that currently tax forgiven PPP loans, including Arizona, Arkansas, Hawaii, Maine, Minnesota, New Hampshire, Virginia, and Wisconsin, bills have been introduced to prevent such taxation.

If you received a PPP loan, and with tax deadlines fast approaching, you should consult with your tax advisor to determine if you will incur a state tax liability for the forgiven loan.


About Per Diem Plus

The Per Diem Plus® - Owner Operators is the only IRS-compliant mobile application that provides automatic trucker per diem and travel-related expense tracking for drivers, motor carriers and owner operators. Per Diem Plus was designed, developed and is managed in the USA.

About the Author

Mark is tax counsel for Per Diem Plus. With nearly two decades of experience advising trucking companies on per diem issues, Mark was responsible for defining the Per Diem Plus software logic rules that automatically calculates trucker per diem in accordance with IRS regulations. He also previously served as the consulting per diem tax expert for Omnitracs.

In addition to his time working with Per Diem Plus, Mark works in private practice as an Enrolled Agent at Mark Sullivan Consulting, PLLC specializing in federal tax controversy representation and consulting. He also served as the consulting and expert witness for the Federal Defenders Office and private defense counsel in financial crimes cases in multiple federal district courts. Contact Mark W. Sullivan, EA


Copyright 2021, 2022 Per Diem Plus, LLC. Per Diem Plus proprietary software is the trademark of Per Diem Plus, LLC.®

Disclaimer: This article is for information purposes only and cannot be cited as precedent or relied upon in a tax dispute before the IRS.

Per Diem Plus daily trip tab screen
Per Diem Plus - Owner Operators

2021 TAX LAW UPDATE - READ ABOUT 100% DEDUCTION FOR PER DIEM


Are self-employed truckers eligible for the refundable tax credit available under the Families First Act?

Yes. As a self-employed trucker you cannot do your job via a ZOOM meeting, thus you are eligible for a refundable tax credit under the Families First Act (FFCRA). You may fund the "sick leave" or "family leave" tax credit by using a portion of the 2020 estimated tax payments that were supposed to be paid quarterly. The refundable credit will be claimed on your Form 1040, U.S. Individual Income Tax Return, for the 2020 tax year.


Specific Families First Act Provisions for Self-Employed Individuals


Who is an eligible self-employed individual for purposes of the Families First Act tax credit?

An eligible self-employed individual is defined as an individual who,

  1. Regularly carries on any trade or business, and
  2. Would be entitled to receive qualified sick leave wages or qualified family leave wages the individual were an employee.

Eligible self-employed individuals are allowed an income tax credit to offset their federal self-employment tax for any taxable year equal to their “qualified sick leave equivalent amount” or “qualified family leave equivalent amount.”

How is the Families First Act tax credit calculated?

The tax credit is calculated by multiplying the number of days you could not work (maximum of 10 days) between April 1 and December 31, 2020 by either:

  • "Sick Leave Equivalent" - $511 or 100 percent of average daily self-employment income, or
  • "Family Leave Equivalent" - $200 or 67 percent of average daily self-employment income

How is the “average daily self-employment income” for an eligible self-employed individual calculated?

Average daily self-employment income is an amount equal to the net earnings from self-employment for the taxable year divided by 260. A taxpayer’s net earnings from self-employment are based on the gross income that he or she derives from the taxpayer’s trade or business minus ordinary and necessary trade or business expenses.

Which credit do I qualify for, the “sick leave equivalent” or "family leave equivalent"?

Which type of "leave" you qualify for depends on the reason(s) you were unable to work. Those that were prohibited from working can claim up to $511/day but those who were home to care for a family member can only claim up to $200/day.

Quarantine / Isolation Orders - "Sick Leave Equivalent"

For an eligible self-employed individual who is unable to work or telework because the individual:

  1. Is subject to a Federal, State, or local quarantine or isolation order related to COVID-19;
  2. Has been advised by a health care provider to self-quarantine due to concerns related to COVID-19; or
  3. Is experiencing symptoms of COVID-19 and seeking a medical diagnosis,

the qualified sick leave equivalent amount is equal to the number of days during the taxable year that the individual cannot perform services in the applicable trade or business for one of the three above reasons, multiplied by the lesser of $511 or 100 percent of the “average daily self-employment income” of the individual for the taxable year.


Example: John was unable to drive due to state-mandated quarantine orders and the absence of loads for 8 days. He had $75,000 or an average of $288/day of self-employment income in 2020.

  • 8 days x $511 = $4,088
  • 8 days x $288 = $2,304

John can claim the lesser amount of $2,304 as refundable credit under FFCRA on his Form 1040, U.S. Individual Income Tax Return.


Caring for Sick Family Member - "Family Leave Equivalent"

For an eligible self-employed individual who is unable to work or telework because the individual:

  1. Is caring for an individual who is subject to a Federal, State, or local quarantine or isolation order related to COVID-19, or has been advised by a health care provider to self-quarantine due to concerns related to COVID-19;
  2. Is caring for a child if the child’s school or place of care has been closed, or child care provider is unavailable due to COVID-19 precautions; or
  3. Is experiencing any other substantially similar condition specified by the Secretary of Health and Human Services in consultation with the Secretary of the Treasury and the Secretary of Labor,

the qualified family leave equivalent amount is equal to the number of days during the taxable year that the individual cannot perform services in the applicable trade or business for one of the three above reasons, multiplied by the lesser of $200 or 67 percent of the “average daily self-employment income” of the individual for the taxable year.

Example: Mary was unable to drive for 10 days because she was home caring for her husband who had been exposed to COVID. She had $65,000 or an average of $250/day of self-employment income in 2020.

  • 10 days x $200 = $2,000
  • 10 days x $168 ($250 x 67%) = $1,680

Mary can claim the lesser amount of $1,680 as refundable credit under FFCRA on his Form 1040, U.S. Individual Income Tax Return.


How does a self-employed individual claim the credits for qualified sick leave equivalent amounts or qualified family leave equivalent amounts?

The refundable credits are claimed on the self-employed individual’s Form 1040, U.S. Individual Income Tax Return, tax return for the 2020 tax year. The Families First Act refundable tax credit is not surprisingly complicated, please consult with your tax advisor.

How should "sick" or "family" leave be substantiated?

Substantiate the days you were unable to work using either of the following methods:

  1. DOT logbook showing "Off Duty" status, or
  2. Per Diem Plus - Owner Operator showing "Not On Trip" status

About Per Diem Plus

The Per Diem Plus® - Owner Operators is the only IRS-compliant mobile application that provides automatic trucker per diem and travel-related expense tracking for drivers, motor carriers and owner operators. Per Diem Plus was designed, developed and is managed in the USA.

About the Author

Mark is tax counsel for Per Diem Plus. With nearly two decades of experience advising trucking companies on per diem issues, Mark was responsible for defining the Per Diem Plus software logic rules that automatically calculates trucker per diem in accordance with IRS regulations. He also previously served as the consulting per diem tax expert for Omnitracs.

In addition to his time working with Per Diem Plus, Mark works in private practice as an Enrolled Agent at Mark Sullivan Consulting, PLLC specializing in federal tax controversy representation and consulting. He also served as the consulting and expert witness for the Federal Defenders Office and private defense counsel in financial crimes cases in multiple federal district courts. Contact Mark W. Sullivan, EA


Copyright 2020-2022 Per Diem Plus, LLC. Per Diem Plus proprietary software is the trademark of Per Diem Plus, LLC.®

Disclaimer: This article is for information purposes only and cannot be cited as precedent or relied upon in a tax dispute before the IRS.

per diem plus owner operators mobile app
Per Diem Plus - Owner Operators

Can an Owner-Operator claim trucker per diem under the related party rule if they own more than 10% of the company?

The 10% ownership - related party rule and per diem creates much confusion. Under the related party rule an Owner-Operator can claim substantiated per diem even if they are the sole owner of the trucking company. However, the related-party restriction imposed by the IRS is frequently misunderstood by both drivers and tax practitioners alike. Based on the foregoing it does not apply to the trucking industry.

Related Party Rule

  • The 10% ownership - related party rule and per diem is found in IRS Rev. Proc 2011-47 section 6.07 - Limitations & Special Rules applies only to per diem that includes lodging, meals & incidental expenses under Section 4.01 and 5 (High-Low Method).
  • The related party rule does not apply to trucker per diem under Section 4.04 - Special Rules for Transportation Industry, which is a meals & incidentals expenses-only per diem.
  • Furthermore, it is section 4.04 that allows an Owner-Operator or a motor carrier that offers a company-sponsored per diem plan to deduct 80% of per diem. 
    • The tax deductibility of per diem is limited to 50% for the other substantiated per diem options governed by Section 4.01 and 5 of Rev. Proc. 2011-47.

TAX LAW UPDATE - READ ABOUT 100% DEDUCTION FOR PER DIEM

Per Diem Substantiation Method


Section 4.01 Per diem allowance:

  • If a payor pays a per diem allowance in lieu of reimbursing actual lodging, meal, and incidental expenses to be incurred by an employee for travel away from home,
  • The amount of the expenses that is deemed substantiated for each calendar day is equal to the lesser of the per diem allowance for that day or,
  • The amount computed at the federal per diem rate for the locality of travel for that day.

Special Rules for the Transportation Industry

Section 4.04 applies to:

  • A payor that pays a per diem allowance only for meal and incidental expenses for travel away from home to an employee in the transportation industry and computes the amount under section 4.02, or
  • An employee or self-employed individual (owner-operator) in the transportation industry who computes the deductible amount for meal and incidental expenses for travel away from home under section 4.03.

Limitations and Special Rules

Section 6.07 applies to:

  • Related parties.
  • Sections 4.01 and 5 of this revenue procedure do not apply if a payor and an employee are related within the meaning of 267(b), but for this purpose the percentage of ownership interest referred to in 267(b)(2) is 10 percent.

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About Per Diem Plus

The Per Diem Plus® - Owner Operators is the only IRS-compliant mobile application that provides automatic trucker per diem and travel-related expense tracking for drivers, motor carriers and owner operators. Per Diem Plus was designed, developed and is managed in the USA.

About the Author

Mark is tax counsel for Per Diem Plus. With nearly two decades of experience advising trucking companies on per diem issues, Mark was responsible for defining the Per Diem Plus software logic rules that automatically calculates trucker per diem in accordance with IRS regulations. He also previously served as the consulting per diem tax expert for Omnitracs.

In addition to his time working with Per Diem Plus, Mark works in private practice as an Enrolled Agent at Mark Sullivan Consulting, PLLC specializing in federal tax controversy representation and consulting. He also served as the consulting and expert witness for the Federal Defenders Office and private defense counsel in financial crimes cases in multiple federal district courts. Contact Mark W. Sullivan, EA


Copyright 2020-2022 Per Diem Plus, LLC. Per Diem Plus proprietary software is the trademark of Per Diem Plus, LLC.®

Disclaimer: This article is for information purposes only and cannot be cited as precedent or relied upon in a tax dispute before the IRS.

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Designed by drivers, built by tax pros

Summary of the 2017 Tax Cuts and Jobs Act (TCJA)

The following article is summary of the impact of the 2017 Tax Cuts and Job Act (TCJA) on truckers The following is a list of common trucker tax deductions that were changed by the TCJA (except where noted).

Miscellaneous Itemized Deductions

The TCJA eliminated itemized deductions for employee drivers, which includes all unreimbursed employee business expenses. The following is a non-exhaustive list:

  • Per diem
  • Communication devices and fees such as cell phones
  • Safety & security devices such as GPS devices
  • Clerical operations such as computer accessories and mailing & fax fees
  • Regulatory licensing (DOT medical)
  • Personal hygiene supplies

This provision does not apply to Owner Operators who claim travel-related and business expenses on Schedule C or Form 1120S.

20% Deduction for Qualified Business Income

IRC Section 199A generally provides a deduction of 20% of qualified business income (QBI) derived from a sole proprietorship, partnerships, or S corporation that is a qualified trade or business. The §199A deduction is taken from adjusted gross income (AGI) in determining taxable income and therefore does not reduce self-employment income. See my article titled "Understanding the 20% Passthrough Deduction" for a detailed discussion of the complicated deduction.

The §199A deduction is complicated and will require significant guidance from the IRS.


Introducing Per Diem Plus Small Fleets, an affordable, customizable per diem solution for solo and team operators

Alimony

The deduction for alimony and separate maintenance payments by the payor is repealed. The payee (recipient) will not be required to include such payments in gross income for divorce or separation instruments executed after December 31, 2018.[i]

Medical Expenses

Medical expenses continue to be deductible to the extent they exceed 7.5% of adjusted gross income (AGI) for 2017 and 2018. For years after 2018 the threshold is 10% of AGI.

Moving Expenses

The moving expense deduction is repealed except for members of the Armed Forces. The exclusion from gross income and FICA wages for employer reimbursed moving expenses is repealed other than members of the Armed Forces.

This provision does not apply to Owner Operators who claim expenses related to moving a business operation on Schedule C or Form 1120S.

State & Local Taxes (SALT)

A taxpayer may claim an itemized deduction of up to $10,000 ($5,000 for married filing separately) for the aggregate of (1) state and local property taxes not paid or accrued in carrying on a trade or business (See IRC Sec. 212), and (2) state and local income taxes (or sales taxes in lieu of income taxes) paid or accrued in the tax year[ii].

This provision does not apply to Owner Operators who claim business-related taxes on Schedule C or Form 1120S.

Home Equity Mortgage Interest

The deduction for interest on home equity indebtedness is disallowed and applies to existing home equity loans. Home equity loans used for business or substantial improvement of a residence may still be deductible[iii]; any used for personal or investment purposes are not[iv].

Charitable Contributions

The base for cash contributions is increased from 50% to 60%. No deduction is allowed for payments to colleges and universities in exchange for rights to purchase athletic seats.

Gambling Losses

All gambling expenses are now subject to the gambling winnings limitation and not just wagers. Schedule A filers can still deduct gambling losses to the extent of winnings but must have total itemized deductions exceeding the increased standard deductions.

Affordable Care Act

The individual tax for failure to maintain minimum essential coverage is reduced to zero with respect to health coverage status for months beginning after December 31, 2018.

New Standard Deduction Amounts

The standard deduction is increased to $24,000 for married filing jointly, $18,000 for head of household, and $12,000 for unmarried (single). The pre-2018 additional $1,250 standard deduction for taxpayers over age 65 or who are blind are retained.

Personal Exemption and Dependency Exemption

Personal exemptions and dependency deductions are repealed. The IRS is examining how the definition of qualifying relative should be addressed.

Head of Household Due Diligence

Section 6695(g) of the internal Revenue Code requires paid return preparers to satisfy due diligence requirements to ensure clients qualify for the American opportunity credit, lifetime learning credit, earned income credit, and child tax credit.


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About Per Diem Plus

Per Diem Plus was born over our 30 years of experience as agents and tax practitioners and a relentless pursuit to introduce efficiency to the time-consuming task of tax compliance for truck drivers, fleets and their accounting professionals. The Per Diem Plus® Fleets enterprise platform enables motor carriers to easily implement an IRS-compliant fleet per diem program in hours that is scalable and data plan-friendly. Per Diem Plus was designed, developed and is managed in the USA and is the only IRS-compliant mobile application that provides automatic trucker per diem for solo and team drivers traveling in the United States and Canada. For more information, contact us at info@perdiemplus.com or visit www.perdiemplus.com

About the Author

Mark is tax counsel for Per Diem Plus. With nearly two decades of experience advising trucking companies on per diem issues, Mark was responsible for defining the Per Diem Plus software logic rules that automatically calculates trucker per diem in accordance with IRS regulations. He also previously served as the consulting per diem tax expert for Omnitracs.

In addition to his time working with Per Diem Plus, Mark works in private practice as an Enrolled Agent at Mark Sullivan Consulting, PLLC specializing in federal tax controversy representation and consulting. He also served as the consulting and expert witness for the Federal Defenders Office and private defense counsel in financial crimes cases in multiple federal district courts. Contact Mark W. Sullivan, EA



Disclaimer: This article is for information purposes only and cannot be cited as precedent or relied upon in a tax dispute before the IRS.

Copyright 2018-2023 Mark Sullivan Consulting, PLLC; Per Diem Plus, LLC. Per Diem Plus proprietary software is the trademark of Per Diem Plus, LLC.®


[i] Notice 2018-37, 2018-18, I.R.B. 521

[ii] IRC § 164(b)(6) (flush language)

[iii] Temp. Reg. § 1.163-8T

[iv] Refer to Publication 936 (2017) Home Mortgage Interest Deduction for definitions of “substantial improvement”

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