Richard Posner 360x1000
Margaret Fuller1 360x1000
8albion'
2confidencegames
1empireofpain
Betty Friedan 360x1000
James Gould Cozzens 360x1000
499
Learned Hand 360x1000
Maurice B Foley 360x1000
3defense
Tad Friend 360x1000
2lafayette
2gucci
4albion
1transcendentalist
Gilgamesh 360x1000
1lauber
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11albion
Margaret Fuller 360x1000
Thomas Piketty2 360x1000
Thomas Piketty1 360x1000
1theleasofus
2transadentilist
3albion
2lookingforthegoodwar
199
storyparadox2
3theleastofus
2theleastofus
1lafayette
2albion
14albion
Samuel Johnson 360x1000
9albion
1falsewitness
7albion
Susie King Taylor2 360x1000
3confidencegames
Stormy Daniels 360x1000
5confidencegames
2trap
storyparadox3
Margaret Fuller4 360x1000
Anthony McCann1 360x1000
399
Brendan Beehan 360x1000
Margaret Fuller 2 360x1000
lifeinmiddlemarch2
1jesusandjohnwayne
12albion
7confidencegames
1confidencegames
Mary Ann Evans 360x1000
Edmund Burke 360x1000
1albion
Lafayette and Jefferson 360x1000
Ruth Bader Ginsburg 360x1000
299
Thomas Piketty3 360x1000
Office of Chief Counsel 360x1000
2defense
10abion
Maria Popova 360x1000
11632
4confidencegames
LillianFaderman
AlexRosenberg
Adam Gopnik 360x1000
6albion
2falsewitness
6confidencegames
5albion
Anthony McCann2 360x1000
1lookingforthegoodwar
George F Wil...360x1000
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lifeinmiddlemarch1
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13albion
Margaret Fuller2 360x1000
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Margaret Fuller3 360x1000
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George M Cohan and Lerarned Hand 360x1000
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1defense
Courts and Value Billing

Courts and Value Billing

The disdain for professional imprimaturs unsupported by work has moved beyond the Son of Boss unbalanced entries to a deal that tax professionals felt deserved a bit more respect. Canal Corporation and Subsidiaries was a deferral deal. Instead of selling a subsidiary the taxpayer contributed it to a partnership and took a large distribution. The debt that funded the distribution was allocated to the contributing partner, which avoids the disguised sale rules. Of course, they didn’t really want a liability, so the guarantee that supported the allocation was pretty tenuous.

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Time to Face the Music

Time to Face the Music

The statute of limitations was closed on years prior to 2004. So the service took the position that the accruals had constituted an impermissible accounting method. This required a cumulative adjustment for all the accruals hitting the couple with just shy of $300,000 in tax and $60,000 in penalties for the 2004 year.

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Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.