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CPA Sinks Under Millions In Aiding And Abetting Penalties On Mariners Deductions

The problem with the position that Kapp was recommending and using in preparing returns and schedules for returns not prepared by him, is that he was using the rate specified for meals and incidentals, which is about ten times the rate for just incidentals.  You see Johnson was just a partial victory.  A nonitinerant sailor is “away from home” when onboard, but only entitled to the much lower incidental per-diem, because the owners of ships have an apparently universal practice of feeding their sailors.

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Joe Biden’s Tax Returns – No Reason Democrats Need To Overpay Their Taxes

You will find case law about taxpayers having income recharacterized because of low S corporation salaries, but I do not think that there are any such cases where the taxpayers were taking six-figure salaries.  The reason for this is probably that there are a lot of C corporation cases where taxpayers are hit for taking salaries that are too high. A recent example was Dr. Afzal Ahmed, who wiped out $2.78 million in profit by taking a bonus.  The IRS disallowed a million of the bonus.

As Rubin notes in his article Newt Gingrich was also criticized for using this technique, and I stood up for him too.

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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.