Partial Dispositions Explained:

Unlocking Losses Under the MACRS Rules

When a taxpayer replaces a roof, HVAC system, plumbing component, or other portion of depreciable property, the remaining basis of the retired component may continue sitting on the depreciation schedule unless the partial-disposition rules are properly applied. This two-hour self-study IRS continuing-education course examines Treasury Regulation §1.168(i)-8, including elective and mandatory partial dispositions, component identification, basis allocation, timing requirements, Form 4797 reporting, late-election procedures, documentation, and audit exposure.

Taught by Patrick Luna, a former IRS LB&I Engineer and national subject-matter expert in depreciation, capitalization, cost segregation, and partial dispositions who helped develop IRS examination guidance and train agents nationwide. 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.

After completing this course, participants should be able to:

  •  Define a disposition

  •  Determine the appropriate disposed asset

  •  Identify the disposed asset and placed-in-service date

  •  Apply the partial disposition rule

  •  Account for a partial disposition

Who should Attend:

This course is designed for enrolled agents, CPAs, tax attorneys, tax preparers, accountants, depreciation specialists, cost-segregation professionals, and other practitioners who prepare, review, or defend tax positions involving building improvements, component retirements, tangible property, and MACRS depreciation.

2 IRS CE Hours

Prerequisites: None

Program Level: Basic

Advanced Preparation: None

Field of Study: Taxes

Location: Virtual

Delivery Method: Self Study

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.

All courses must be completed by 12/31/2026 to receive IRS CE Credit

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