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

Most Recent Posts

Bristol Palin At Heart Of IRS Scandal – Who Knew?

So what we have is a reflexive anit-conservative appointed to head the IRS Exempt Group during the Bush administration by an IRS Commissioner appointed by Bush.  Is it possible that the big money Republicans figured that they had the IRS exempt group outgunned, but that a reflexive anti-conservative in that position would be tough on the more conservative part of the party? The other thing that the report mentions is that during the whole period of the scandal no audits of exempts were initiated over the political spending issue.  So the established dark money organizations were let off scot-free.  All the grief went to the Tea Party insurgents who were least able to cope with it.

read more
IRS Scandal – Blame It All On Lois Lerner And Move On?

IRS Scandal – Blame It All On Lois Lerner And Move On?

Republicans have been hoping that there would be a smoking gun in all those interviews and documents.  I mean wouldn’t it be great if there were a taped conversation in which President Obama ordered the IRS to harass the Tea Party. Senator Wyden indicates that nothing anywhere near to that has turned up.  Senator Hatch, on the other hand, thinks the smoking gun has been hiding in plain sight.

Regardless of whether an explicit directive was given, the President gave the order to target conservative groups at every opportunity – the State of the Union, in press conferences, and in TV interviews. He didn’t send a “smoking gun” email because he did not need to – he gave the order for all to hear. And his political allies at the IRS followed those orders

Senator Wyden in his statement points out the inconvenient facts that the IRS Commissioner at the time had been appointed by President Bush and that Lois Lerner had been promoted to head the Exempt Organization group by a Bush appointed IRS Commissioner. Go figure. So I guess the TaxProf can keep the count going.

read more
IRS Says Charitable Trust Not Charitable Enough

IRS Says Charitable Trust Not Charitable Enough

The Schaefer case is about a charitable estate tax deduction for two NIMCRUTs.  You start out with the value of the assets in the trusts and then you do some fancy math – life contingencies combined with present value – to divide that between the income interest and the remainder interest.  The latter is deductible either for estate tax purposes as in this case or as an income tax deduction.  If the remainder interest computes to less than 10% of the overall value, no charitable deduction is allowed.

The higher the payout ratio, the lower the value of the remainder.  One of the trusts had a payout rate of 10% and the other was 11%.  Both the IRS and the executor agreed that with that payout the charity would be getting less than 10% of the value.  The executor argued that in doing the valuation the net income limit should be taken in account.  Apparently there was some sense that the trust would not hit that target rate.  The Tax Court wanted them to also consider using 5%, which is the minimum allowed payout rate.

read more
Citizens United Fighting To Keep Dark Money As Dark As Possible Loses To NY AG

Citizens United Fighting To Keep Dark Money As Dark As Possible Loses To NY AG

In addition to the IRS exempt organizations that solicit money are also regulated by the states where they raise money. There are various filings required, sometimes much more rigorous than what the IRS requires.  As part of the package though, they will usually want a copy of the Form 990 that the organization files with the IRS.  That’s the way it is in Massachusetts anyway and apparently in New York too. CU had been sending the New York AG its 990 since 1995. They had not been including Schedule B and nobody seemed to mind.  The Charities Bureau conducted a survey of its operations in 2012 and noticed that certain organizations were not including Schedule B with annual reports.  The AG implemented an across-the-board initiative to identify and notify the organizations that had not been filing Schedule B with their state reports.  In April 2013 the CU organizations were notified that their filings were incomplete.

read more