Margaret Fuller3 360x1000
1empireofpain
2gucci
Margaret Fuller5 360x1000
George M Cohan and Lerarned Hand 360x1000
1lookingforthegoodwar
Brendan Beehan 360x1000
Learned Hand 360x1000
Maria Popova 360x1000
10abion
1madoff
3paradise
2paradise
499
Stormy Daniels 360x1000
6confidencegames
11632
1albion
Margaret Fuller1 360x1000
1confidencegames
2jesusandjohnwayne
13albion
Adam Gopnik 360x1000
1defense
8albion'
2transadentilist
2lafayette
Thomas Piketty2 360x1000
Office of Chief Counsel 360x1000
storyparadox3
7albion
Samuel Johnson 360x1000
2theleastofus
5albion
Betty Friedan 360x1000
Edmund Burke 360x1000
Gilgamesh 360x1000
Mary Ann Evans 360x1000
3theleastofus
1gucci
1trap
Maurice B Foley 360x1000
Mark V Holmes 360x1000
5confidencegames
1jesusandjohnwayne
Spottswood William Robinson 360x1000
1transcendentalist
James Gould Cozzens 360x1000
2trap
Anthony McCann2 360x1000
lifeinmiddlemarch1
4albion
2confidencegames
Thomas Piketty3 360x1000
Storyparadox1
4confidencegames
11albion
14albion
Anthony McCann1 360x1000
AlexRosenberg
12albion
3albion
1theleasofus
3defense
Thomas Piketty1 360x1000
Tad Friend 360x1000
Lafayette and Jefferson 360x1000
2defense
1falsewitness
299
Margaret Fuller4 360x1000
3confidencegames
1lafayette
9albion
Margaret Fuller 2 360x1000
199
Richard Posner 360x1000
2falsewitness
399
1paradide
LillianFaderman
George F Wil...360x1000
2lookingforthegoodwar
1lauber
2albion
Susie King Taylor 360x1000
storyparadox2
lifeinmiddlemarch2
Margaret Fuller 360x1000
6albion
Susie King Taylor2 360x1000
Ruth Bader Ginsburg 360x1000
Margaret Fuller2 360x1000
7confidencegames
IRS Cracking Down On Easement Donation Syndications

IRS Cracking Down On Easement Donation Syndications

Given the high value of the castles in the air that some appraisers can conjure, you can see that ultimately the owners of property have much more in the way of potential tax benefit than they can use themselves even with the generous 50% adjusted gross income limitation and 15 year carryover.  That’s where syndication comes in.

A year or so ago, thanks to all I have written about conservation easements, I received a call from someone who was promoting the syndication of conservation easements.  In order for it to work I figured that one of three things had to be going on.  There was fast and loose playing with Code Section 704, which concerns how you allocate income and losses among partners, property was being acquired from very dumb people or they were, you know, fibbing about the valuation.  I think the proportions may vary, but that the third element, the valuations, tends to predominate.  At least that is what the IRS is implying.

read more

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.