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Aggressive Life Insurance Plan Fails – Or Maybe Not

Aggressive Life Insurance Plan Fails – Or Maybe Not

This was originally published on PAOO on August 13, 2010. One of my favorite plays is Guys and Dolls.  My daughter and I occasionally attempt to sing Sit Down You’re Rocking the Boat.  You should be glad this is a text blog and not You-tube.  Trust me.  At any...
Does Tax Court Ruling on Gender Reassigment Go Far Enough ?

Does Tax Court Ruling on Gender Reassigment Go Far Enough ?

  ParaDox Rhiannon G. O’Donnabhain (134 TC 4) This was originally published on PAOO on August 12th, 2010. It was my first coverage of transgender issues. There has not been much on the deductibility of gender reassignment. In 1983 PLR 8321042 allowed the...
You Have to be Able to Keep Your Face Straight

You Have to be Able to Keep Your Face Straight

This was originally published on PAOO on August 9th, 2010. Willie J. Moore, et ux. v. Commissioner, TC Summary Opinion 2010-102 is a good illustration of the principle that Summary opinions make up in entertainment value what they lack in precedent. The issue was car...
Guess me Out of the Ballpark

Guess me Out of the Ballpark

Martin Péchy at Pexels Originally published on PAOO on August 6, 2010 The case of Marcel Ajah (TC Summary Opinion 2010-90) is about the ultimate oxymoron – “passive activities”. The concept of passive activities embodied in Section 469 is a creature...
It Doesn’t Have to Be a Good Idea

It Doesn’t Have to Be a Good Idea

This was originally published on PAOO on August 4th, 2010. Image by Maisfenghui. Tax court summary opinions lack value as precedent. They frequently make up for it in their entertainment value. They also give a better glimpse of the gritty reality of audits. They...
Investment Interest Relief

Investment Interest Relief

PLR 201016032 This was originally published on PAOO on July 30th, 2010. If you are someone who invests on margin PLR 201016032 might be of interest to you (pardon the unintentional pun). Back in the good old days interest used to be just deductible. Yeah, they got...