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Tax strategies · Code sections and court cases

Tax strategies backed by the Code and the Tax Court.

Every strategy on these pages is tied to the Internal Revenue Code section that allows it and the court decisions that show where it fails. We use them when the facts support them, document them as we go, and defend them if the IRS asks.

Built on
IRC § 168(k)IRC § 41IRC § 469IRC § 179IRC § 280A(g)Rev. Rul. 74-44

Strategies

Choose a strategy to see the rules, the cases and how we apply it.

Tax strategy

Bonus Depreciation and Cost Segregation

How 100% bonus depreciation under IRC section 168(k) and cost segregation studies work in 2026 for commercial buildings, rentals, hotels and medical offices, with the Tax Court cases that set the limits.

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Tax strategy

R&D Tax Credit (IRC Section 41) and Section 174A Expensing

The research credit under IRC section 41 and immediate R&E expensing under section 174A: who qualifies, the four-part test, the $500,000 payroll offset, documentation, and the Tax Court cases that decide R&D claims.

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Tax strategy

Real Estate Professional Status (IRC Section 469(c)(7))

How real estate professional status under IRC section 469(c)(7) lets rental losses offset other income: the 750-hour and more-than-half tests, material participation, the aggregation election, records, and Tax Court cases.

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Tax strategy

Short-Term Rental Tax Strategy (7-Day Rule and Material Participation)

How short-term rentals such as Airbnb and Vrbo properties can generate nonpassive losses under Treas.

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Tax strategy

Equipment Rental and Leasing Tax Rules

Tax rules for owning and leasing equipment: section 179 limits for noncorporate lessors, bonus depreciation, the passive activity and self-rental rules, at-risk limits, true lease versus financing, and the Tax Court cases behind them.

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Tax strategy

Medical Device and Medical Equipment Tax Strategies

Tax strategies for medical and dental practices buying equipment, and for medical device companies: section 179 and bonus depreciation, leasing, the disabled access credit, the R&D credit and section 174A, the repealed device tax and QSBS.

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Tax strategy

S Corporation Reasonable Compensation

How much salary an S corporation owner must take: the reasonable compensation rule, Rev.

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Tax strategy

Augusta Rule (Section 280A(g)) and Hiring Family Members

The Augusta rule under IRC section 280A(g), which excludes rent for 14 days or less, and paying your children through the family business under IRC 3121(b)(3)(A): requirements, documentation and the Tax Court case that tested them.

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Hospitality

Tax and Advisory for Hotel Owners and Franchisees (Marriott, Hilton, IHG and More)

Tax, audit and advisory for owners of franchised hotels such as Marriott, Hilton, IHG, Hyatt and Choice brands: 100% bonus depreciation, cost segregation, PIP renovations, franchise fees, passive loss planning, tips, occupancy and BPOL taxes.

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Tax credits & incentives

2026 Business Tax Credits and Incentives: R&D, Solar, Bonus Depreciation

Where business tax credits and incentives stand for 2026 after the 2025 tax law: R&D credit and section 174A expensing, solar and clean energy credits, 100% bonus depreciation, section 179, childcare and paid leave credits, and what expired.

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Questions

Frequently asked

If your question isn't here, call (703) 880-8412 and you'll reach a person.

Are these strategies legal?

Yes, each is based on a specific Code section or regulation. Problems arise when the facts do not fit the rule or the records do not prove it, which is what the cases on each page show.

Which strategy fits my situation?

It depends on your income, entity type, property and how you spend your time. We model the options against your returns before recommending any of them.

Will a strategy increase my audit risk?

Some, such as real estate professional status and large R&D claims, draw more attention. Contemporaneous documentation is what makes them hold up.

Do Virginia and other states follow these rules?

Not always. Virginia does not follow federal bonus depreciation, and states differ on research expensing and credits.

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