Partial Dispositions Explained:
Unlocking Losses Under the MACRS Rules
This course provides a practical and technical examination of partial dispositions of MACRS property under Treasury Regulation §1.168(i)-8. Designed for tax practitioners who advise on repairs, improvements, remodels, and asset retirements, the course explains when a partial disposition may or must be recognized, and how the election impacts depreciation, gain or loss recognition, and audit exposure.
Participants will review the statutory and regulatory framework governing partial dispositions, including eligibility requirements, assets subject to the rules, and situations in which partial disposition treatment applies automatically. The course covers the partial disposition election, timing requirements, revocation limitations, and the distinction between current-year elections and late partial disposition elections under applicable revenue procedures.
This course emphasizes compliance, documentation, and examination considerations, making it well suited for practitioners involved in tax return preparation, review, planning, or audit defense involving depreciable real property and improvements.
In this course, you will be able to:
Who should attend:
CPAs, EAs, tax professionals who want to learn more about partial dispositions
2 IRS CE hours
2 CPA CPE Credits
Prerequisites: None
Program Level: Basic
Advanced Preparation: None
Field of Study: Taxes
Location: Virtual
Delivery Method: Group Internet Based
Your Instructor
Patrick Luna
Former IRS Subject Matter Expert
Patrick Luna is a former IRS Engineer with more than 40 years of experience in the Internal Revenue Service’s Large Business & International Division. For over 30 years, he examined large corporate taxpayers, concentrating on complex depreciation and capitalization issues. He also served as an expert witness in multiple cost segregation court cases, including several of the most recently decided cases in this area.
During the final decade of his IRS career, Patrick functioned as a national subject matter expert in depreciation, cost segregation, capitalization, and partial dispositions of tangible property. In that capacity, he advised revenue agents and engineers across the country, developed technical training materials, and delivered instruction to LB&I personnel nationwide. He contributed to Industry Issue Resolutions addressing capitalization matters and played a key role in drafting and updating the Capitalization of Tangible Property Audit Technique Guide and related Practice Units published on IRS.gov.
Patrick was a lead member of the national subject matter expert team responsible for providing technical guidance, resources, and training on partial dispositions of depreciable property. His experience offers practitioners rare insight into how the IRS analyzes, develops, and resolves tangible property and cost segregation issues in large case examinations.
Next Webinar:
5/26/2026
1:00 PM Eastern
Partial Dispositions Explained: Unlocking Losses Under the MACRS Rules
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