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

TIGTA Alimony Report May Cause Crisis Of Conscience Among Tax Professionals

The bottom line is that I used to believe that when I was telling people to do the right thing, I was also telling them to do the smart thing – that the risk of non-compliance outweighs the benefits.  That confidence has been eroding in me for some time with respect to people who just want to maximize their lifestyle and are not too worried about their credit rating, but knowing now that something so blatantly wrong will more than likely slide by, not because the IRS can’t find it, but just because they lack the resources to look into it is very disturbing.

read more
Real Estate Dealer Or Investor – Can’t Switch At Drop Of Hat

Real Estate Dealer Or Investor – Can’t Switch At Drop Of Hat

I’m just a lowly CPA, but I think a critical point was missed in the decision.  The Court attributes everything that happened from 2002 on to Mr. Boree.  If Glen Falls LLC was a partnership up till 2005, what happened before then was not relevant.  Mr. Boree gets a fresh start in his purpose in holding the property at the deemed liquidation of the partnership.  By conflating the two, the Tax Court appears to be contradicting its holding in the Phelan decision.  Of course, it appears that Mr. Boree did not really take advantage of the fresh start.  Nonetheless, I think that more careful planning and the introduction of one or more special-purpose entities might have enabled Mr. Boree to achieve capital gains treatment on a significant part of the transaction.

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.