Sawyer Taxi Heirs Midcoast Fortrend Deal – Could Have Been Worse
In the end, the Sawyer Trust is not responsible for the entire corporate tax that Fortrend dodged, but it does have to give back the premium it received over the net asset value of the companies it sold (Cash on hand less correct corporate tax). The IRS had wanted to get nearly $20 million in corporate tax from the Trust. The decision limits the recovery to $13.5 million, before interest and penalties. It is still quite painful when you consider that an S election in 1987 would have legitimately avoided the entire problem.
IRS Chief Counsel Has To Decide If Nail Polish Is A Luxury
Taxpayer’s contributions of wrinkle creams, hair gels, perfumes, hair sprays, hair texturizers, curling irons, hair dyes, nail polishes, epilators, and hair restoration treatments (the “Donated Products”), are not “qualified contributions” that are eligible for the enhanced deduction under I.R.C. § 170(e)(3), because they are not needed for the care of the ill, the needy, or infants under I.R.C. § 170(e)(3)(A)(i) and Treas. Reg. § 1.170A-4A(b)(ii).
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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.