PPP IRS And Tax Deductions – Is Resistance Futile?
Originally published on Forbes.com. A Treasury news release makes it clear that the IRS is holding firm to its negative view on deducting expenses paid by forgivable...
IRS Threatens 75% Fraud Penalty For Investors In Syndicated Conservation Easements
The answer is the same for both types of partnerships. The fraud penalty is determined at the partnership level. In order to assert the fraud penalty the IRS must prove “by clear and convincing evidence, the elements of the fraud penalty based on the partnership-level conduct and intent of the manager(s) of the partnership”. What the investor partnersh though is really not relevant.
Ms. Black makes it clear that there is nothing different about SCEs in this regard compared to other partnerships.
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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.