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IRS Declines Rubbing Salt in The Wound

IRS Declines Rubbing Salt in The Wound

Originally published on PAOO. It’s getting a little stale, so I think I should post now on Rev Proc 2010-14 (issued March 5, 2010) or forever hold this piece.  Although it is a taxpayer-favorable ruling, its recipients are probably not dancing in the streets. ...
Deemed Partnership

Deemed Partnership

  This was originally published on PAOO. The case of Holdner v Com TCM 2010-175 is giving me pause.  When I read what William Holdner and his son Randal achieved over the years in business  I am very impressed.  Mr. Holnder seems a much sharper businessman than I...
Real estate election relief

Real estate election relief

This was originally published on PAOO on September 6th, 2010. When I titled this blog Passive Activities and Other Oxymorons, it was by no means, because I intended to write only on the passive activity loss rules.  If I was going to totally devote myself to one tax...
Pigs Get Fed

Pigs Get Fed

Photo credit Oscar Roberto Martinez Lopez. This was originally published on PAOO on September 3rd, 2010. You can see in this post some of the early development of Reilly’s Laws of Tax Planning. I’ve been struggling with the title for this particular post. ...
Need Form for Dependency Deduction

Need Form for Dependency Deduction

Gratisography at Pexels This was originally published on PAOO on September 1st, 2010. I’ve told a couple of sad stories of damsels in distress who the Tax Court couldn’t help.  Well here’s hoping for a little schadenfreude for Caron...
LLC Member Not Presumed to be Passive

LLC Member Not Presumed to be Passive

This was originally published on PAOO on August 30th, 2010.   In Action On Decision 2010-002 the IRS acquiesced in a Court of Claims decision (Thompson v. US 104 AFTR 2d 2009-5381) holding that a membership interest in a LLC was not presumptively passive.  Since...