It’s Not Just Us Taxapyers That’s Confused
Suppose, though, that you invest in a partnership and that that partnership invests in some other partnership. What happens is that the partnership you invest in jumps through hoops and then you jump through hoops. The ruling above is reminding agents that the basis hoop and the “at-risk” hoop even though they look a lot alike are not exactly the same. Only individuals and closely held corporations need to be at-risk.
They’re From the Government and They’re Not There to Help You
I agree that we can assert increased income and leave it to taxpayer to raise his entitlement to disputed losses.
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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.