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

Most Recent Posts

Kent Hovind Homecoming

Kent Hovind Homecoming

I don’t doubt Hovind’s sincerity.  Among the “authorities” he cites is Irwin Schiff.  Doctor Ward Dean, who was kind of one of Hovind’s Pensacola anti-IRS battle buddies and a friend of Don Camacho from their service together in the Escambia Country Militia,  continues to believe that the theories are correct even after serving a long prison sentence for following them.

read more
Something Borrowed Makes You Blue – Student Debt And Joint Returns

Something Borrowed Makes You Blue – Student Debt And Joint Returns

From a policy point of view, the current system, if you can call it that, makes no sense at all.  The message graduate schools can now send to a highly indebted student is that further increases in debt never have to be paid back, so there is no point in being price-conscious.  It is as if we have consigned an entire generation to be in a permanent state of work-out.

read more
Jeffrey Webber’s Cayman Insurance Shelter Nixed By Tax Court

Jeffrey Webber’s Cayman Insurance Shelter Nixed By Tax Court

Mr. Webber established a grantor trust that purchased “private placement” variable life insurance policies insuring the lives of two elderly relatives (That’s the ghoulish part).  The premiums paid to Lighthouse Capital Insurance Co. (Cayman Islands) after deduction for mortality risk and administrative charge were placed in separate accounts.  The accounts were segregated and invested in start-up companies that Mr. Webber was intimately familiar with.  They did quite well.

read more
Mario Biaggi’s Criminal Case Followed By Tax Travails

Mario Biaggi’s Criminal Case Followed By Tax Travails

Biaggi appealed to the Second Circuit, objecting to the failure of the IRS to release special agent reports that were submitted to the Grand Jury and on the valuation issue, but had not luck.

An interesting point that I have not been able to determine is whether the IRS ended up whipsawing the Biaggi family.  The assessment for Mario Biaggi not reporting the income from the grant of Wedtech stock relied on the six year statute.  So was it too late for Richard Biaggi to claim a refund for the income that he had over-reported?  Perhaps a protective refund claim went in early in the game.

read more
SpongeBob SquarePants In A Tax Case!

SpongeBob SquarePants In A Tax Case!

The Greenbergers also tried an estoppel argument maintaining that since the Department of Justice had notified them that they might be victims of a crime, that the government could not now argue that they were not theft victims.  That just didn’t work because Ohio law requires a privity between the thief and the victim.

There is probably not much of a tax planning point here since nobody plans to get defrauded.  The fraud story is a really good one, though.  I can’t rate it that highly since the basis was simply inflating sales, but I do think they should get some extra credit for including an animated character.

read more
Chief Counsel Gives Narrow Scope To Partnership Liability Regulations

Chief Counsel Gives Narrow Scope To Partnership Liability Regulations

At any rate, it was nice to have those regulations, because sometimes it is important how the liabilities are allocated among the partners and what flavor the liabilities are.  One situation where it is important whether liabilities are recourse or nonrecourse is when property is foreclosed.  If the liability is recourse, the balance is considered proceeds of sale to the extent of the fair market value of the property and the balance is income from the discharge of indebtedness.  If the liability is nonrecourse, it is all proceeds of the sale.  Which one is better?

read more

In Defense Of Conservation Easement Charitable Deductions

The truth is that these 70 plus cases represent a very small minority of land conservation activities across the nation. There are more than 1,700 land trust working at the local level to preserve wildlife habitat area, ecosystems that produce clean water and air, scenic rural landscapes and recreation areas, historic sites such as civil war battlefields, and productive agricultural and forestry resources that supply our nation with food and timber.

Working within their own community these groups have harnessed local enthusiasm and voluntary action to permanently preserve and protect as much as one million acres per year. Since the 1970’s, there have been tens of thousands of conservation easements donated on tens of millions of acres to conservation groups across the nation.  The cases brought by the IRS and state tax departments represent far less than 1 percent of the donations that happen in even one year.

read more
Joan Farr Claims IRS Denial Of Exempt Status Is Example Of Persecution Of Christians

Joan Farr Claims IRS Denial Of Exempt Status Is Example Of Persecution Of Christians

Ms. Farr indicated that AHA had never grossed more than $25,000 meaning it never had to file a complete Form 990.  Based on the drama about the loan balance, it was clear that nobody was maintaining a general ledger.  Revenue agents are trained as accountants and it makes accountants happy when they have a general ledger with everything classified.  I also have to say that having an entity pay back your loan by paying your bills for you is a very bad idea.  If there had been a general ledger with those items charged to the officer loan accountant that would have been better, but much better would be the two step process of a loan repayment via a check to Ms. Farr and her paying the bills out of her personal account.

read more
Campaigning For Bishopric Not A Valid Exempt Purpose – Kent Hovind Update

Campaigning For Bishopric Not A Valid Exempt Purpose – Kent Hovind Update

It strikes me as something of a compromise between hierarchical churches where bishops are appointed and churches with extreme congregational independence.  If you locked a bunch of Catholics who wanted things more democratic and Southern Baptists who wanted things more organized in a room and told them they had to agree on a governance model for the Southern Catholic Convocation, it might be what you would end up with – or not.

read more