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Should You Invest In A Syndicated Conservation Easement ?

by | Dec 23, 2022 | Tax

As somebody who believes that the syndicated conservation easements (SCE) constitute an industry based on nonsense, I want to be able to tell you that if you are offered the chance to participate in one, you absolutely should not. I can’t really do that though. ...
IRS Successfully Attacks Tax Shelter With Hobby Loss Rule

IRS Successfully Attacks Tax Shelter With Hobby Loss Rule

by | Dec 15, 2022 | Tax

Tenth Circuit upholding the Tax Court’s ruling in the case of Preston Olsen may signal the revival of a once successful IRS technique for attacking tax shelters.  Code Section 183 – Activities not engaged in for profit – is commonly rereferred to as...
Conservation Easement Syndicates Outlawyering IRS

Conservation Easement Syndicates Outlawyering IRS

by | Dec 2, 2022 | Tax

The full Tax Court in one of its regular decisions (Green Valley Investors LLC) has dealt a blow against the IRS in its struggle with abusive syndicated conservation easements.  A key IRS move in the fight was Notice 2017-10 which made certain syndicated conservation...
On Tax Writing Rabbit Holes

On Tax Writing Rabbit Holes

by | Nov 30, 2022 | Tax

In an upcoming issue of Think Outside The Tax Box , there will be a piece by me about the current state of the Cohan rule. In 1930 Learned Hand writing for the Second Circuit instructed the Board of Tax Appeals (the predecessor to the Tax Court) to take another look...
MR. REILLY’S CONUNDRUM

MR. REILLY’S CONUNDRUM

by | Nov 30, 2022 | Tax

My favorite tax blog, by a long shot, is Taishoff Law.  I first learned of it because of the way I have done my own blogging.  I read original source material and come up with my own take on it.  As part of my wrap-up I then see what other have had to say. I then...