Most Recent Posts
Blessed Are The Peacemakers – Appomattox Sesquicentenniial
Yesterday, although not technically the sesquicentennial of the last day of the Civil War, is recognized as such in popular imagination and not without reason....
Tax Court Allows Multimillion Multiyear Arabian Horse Losses
If you told that story to some CPAs who had been in the business a long time, you would get two different reactions. One would be a kind of “There but for the grace of God, go I” and another would be “Well that would never happen with a transaction that my firm was involved with. We have procedures and policies to avoid that type of thing”. The latter group is divided into two classes – people who are deluding themselves and liars. The humility of the “grace of God” crowd actually makes it less likely that they’ll screw up that way because they will have a couple of paranoid partners who worry about stuff like that happening.
At any rate, the Metzes “reliance on professional” defense did not work, since they should have noticed that a gain of $2 million or so had slipped through the cracks and they were hit with the accuracy penalty. Have to wonder whether that will end up coming out of somebody’s malpractice coverage
Appomattox Gearing Up For Surrender
150 years ago yesterday, the prospects of the Army of Northern Virginia got even dimmer. Its second to last battle was fought in the evening as cavalry under the...
Still Some More Blood To Effuse
Lynchburg VA April 8, 2015 150 years ago yesterday Ulysses Grant wrote Robert E Lee indicating that he thought maybe that recent events should have indicated that the...
Kent Hovind Trials – Final Round Of The First Fight – Installment One
In mid March as I struggled with corporate extensions and continued wrestling with the tangible property regulations, my friend, filmmaker Jonathan Schwartz was in...
IRS Agent Causes Grief For Taxpayer’s Spouse By Being Helpful
Generally, pursuant to section 6011(a) a taxpayer obligated to file a Federal tax return must conform to the forms and regulations prescribed by respondent. Even though signed by petitioner and Mr. Rodriguez, the consent is hardly a form described in section 6011 or section 1.6011-1, Income Tax Regs. Furthermore, a Form 4549 is not signed by the taxpayer under penalties of perjury, one of the critical requirements for a document to be treated as a Federal income tax return. Petitioner’s argument that the consent should be treated as a joint return is rejected.
Real Timing Appomattox During Tax Season
So for the first time in over thirty years I'm playing major hooky in tax season. I'm hitting the road tomorrow to head to Appomattox. The famous conference between...
Bill Caplinger Says You Can’t Be A “Thug For Jesus”
Independent Baptist minister and young earth creationist Kent Hovind nearing the end of a long federal prison sentence finds himself facing new charges. His trial in...
Another Proof That S Corp Can Be Best Choice For Professional Practices
Anybody with a professional practice netting anywhere above the very low six figures needs to have an extremely good reason to consider continuing as a C corporation in light of this and similar decisions. Also this is probably another sign that using S corporations to avoid some, but not all, payroll tax is a very solid strategy.
Zombies Can’t File Tax Court Petitions
Unlike a traditional statute of limitations, the 90-day period of section 6213(a) generally cannot be tolled or extended. Jurisdictional statutes such as section 6213(a) are conditions on the waiver of the Federal Government’s sovereign immunity and must be strictly construed. Section 6213(a) provides that a petition may be filed by the taxpayer during the 90-day period. Petitioner’s suspension under Cal. Rev. & Tax. Code sec. 23301 deprived it of the capacity to sue under section 6213(a) and prevents its corporate revival from prejudicing respondent’s defense of lack of subject matter jurisdiction.