Advanced

Hobby Loss Rule (Section 183) Defense

Drafts a defense for business losses to prove a profit motive to the IRS.

Draft a defense memo for the {business_activity} activity of {taxpayer_name}, which has shown losses for {consecutive_years} years. Address the 9 factors of Treasury Reg. 1.183-2(b), focusing on: 1. Manner of carrying on activity, 2. Expertise, 3. Time and effort expended, and 4. Expectation of asset appreciation.

Related Prompts

Tax
Intermediate

Depreciation book vs tax (MACRS/IFRS) schedule tie-out

Compares book depreciation to tax depreciation, identifies differences, and prepares supporting schedules. Useful for both compliance and provision teams.

GPT-5.2 Thinking; GPT-4.1; o3-mini
0
0
41
Tax
Advanced

Transfer pricing local file outline with functional analysis

Drafts a local file outline including functional analysis, intercompany transactions, and economic analysis placeholders. Useful for TP teams assembling documentation efficiently.

GPT-5.2 Thinking; GPT-4.1; o3-mini
0
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26
Tax
Intermediate

Tax research memo template (issue, facts, analysis, conclusion)

Produces a structured tax research memo with clear issue framing, facts, analysis, and conclusion placeholders. Useful for staff and seniors standardizing technical writing quality.

GPT-5.2 Thinking; GPT-4.1; o3-mini
0
0
28