IRS Successfully Attacks Tax Shelter With Hobby Loss Rule
So the lenses were never actually placed in service. There were basis issues with the way they were financed. There was no meaningful participation by the Olsens to satisfy the requirements of Section 469. Other than that Mrs. Lincoln how did you enjoy the play? Well there is also 183 to worry about.
Conservation Easement Syndicates Outlawyering IRS
This is not the first time that APA has been used against the IRS in the conservation easement fight. In the Hewitt decision in the Eleventh Circuit nearly a year ago the court invalidated a regulation interpreting the perpetuity requirement. In the Court’s opinion Treasury had not given sufficient consideration to a comment submitted by the New York Land Conservancy.
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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.