Tad Friend 360x1000
2defense
Anthony McCann2 360x1000
199
Margaret Fuller3 360x1000
3albion
1albion
2theleastofus
Margaret Fuller2 360x1000
Anthony McCann1 360x1000
11632
1jesusandjohnwayne
2transadentilist
2lookingforthegoodwar
Samuel Johnson 360x1000
2paradise
6confidencegames
Mark V Holmes 360x1000
Margaret Fuller1 360x1000
Stormy Daniels 360x1000
Thomas Piketty1 360x1000
1lookingforthegoodwar
8albion'
4confidencegames
1lafayette
299
2jesusandjohnwayne
lifeinmiddlemarch2
1falsewitness
Thomas Piketty2 360x1000
Betty Friedan 360x1000
3defense
Richard Posner 360x1000
Maria Popova 360x1000
George M Cohan and Lerarned Hand 360x1000
Maurice B Foley 360x1000
Spottswood William Robinson 360x1000
2confidencegames
lifeinmiddlemarch1
Margaret Fuller 360x1000
2lafayette
499
Office of Chief Counsel 360x1000
1confidencegames
Edmund Burke 360x1000
Gilgamesh 360x1000
13albion
Ruth Bader Ginsburg 360x1000
9albion
7confidencegames
2falsewitness
AlexRosenberg
1paradide
Brendan Beehan 360x1000
Storyparadox1
1trap
Margaret Fuller 2 360x1000
2trap
LillianFaderman
James Gould Cozzens 360x1000
1empireofpain
6albion
4albion
3confidencegames
Susie King Taylor 360x1000
5albion
3theleastofus
3paradise
1defense
399
1theleasofus
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storyparadox3
1madoff
1gucci
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2albion
Learned Hand 360x1000
Margaret Fuller5 360x1000
12albion
14albion
2gucci
Thomas Piketty3 360x1000
10abion
1lauber
1transcendentalist
Mary Ann Evans 360x1000
Margaret Fuller4 360x1000
7albion
11albion
George F Wil...360x1000
Adam Gopnik 360x1000
5confidencegames
Lafayette and Jefferson 360x1000

This was originally published on PAOO on 6/8/10.

Private Letter Ruling 201016097

There is a bit that Steve Martin does where he tells you how to make a million dollars and pay no income tax. It’s a very simple plan. First you make one million dollars. Then you pay no income tax. He then addresses the possibility that the IRS might contact you. Simple. You just say “I forgot”.

Any time I see something of such elegant simplicity I want there to be something to it. Some kernel of truth hidden in the nonsense. When it came to Steve Martin’s routine, though, I despaired Until now.

Private Letter Ruling 201016097 was not directed to Steve Martin. The ruling is directed to a taxpayer who is 82 and according to Wikipedia, Steve was born in 1945. Nonetheless it finally vindicates him as a tax advisor. The taxpayer withdrew all the money from a Roth IRA and failed to put it into a rollover Roth within 60 days. The head note to the ruling indicated that the failure was “due to her mental health conditions which affected her ability to handle her financial affairs”. (That “her” is another clue that it wasn’t Steve Martin, himself, applying for the ruling). More on the gender issue follows.

I thought we might be heading to a punch line involving you have to be crazy to blow a roll over deadline, but I was delighted on deeper reading to find an illustration of the Steve Martin Rule (We need to specify Steve to avoid confusion with Martin Ice Cream, a key decision on personal good will). As we read about Taxpayer A moving funds from IRA Account X to non IRA account Y at financial institution M. We find “Taxpayer A represents that he suffers from a condition which impairs his memory.” There it is. “I forgot.” Whether the memory issues having anything to do with the gender transformation between the head note and the third paragraph is a question left unanswered.

Taxpayer A was granted relief. He or she may have forgotten about the whole thing by now, but the rest of us can remember the next time we are in a jam to say “I forgot.”

Oh by the way :

Any tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein