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Most Recent Posts

Tax Court Rules That Being Accommodation Party In Tax Shelter Is Hard Work

Tax Court Rules That Being Accommodation Party In Tax Shelter Is Hard Work

Jason Chai received a masters degree in architecture from a university in Massachusetts.  It was founded as a seminary for Congregational ministers and counts among its graduates Thomas Wentworth Higginson, one of the earlier biographers of Maragaret Fuller, the first woman granted admission to the college library, and Theodore John Kaczynski, the Unabomber.   The school, called Harvard, is about 40 miles east of Worcester.

That’s where Jason Chai met Andrew Beer.  Jason started his architecture career in Los Angeles, but moved to New York in 1999.  He stayed with his Harvard buddy for a while when he first moved to New York.  Andrew ended up marrying Jason’s cousin.  Jason has been a pretty successful architect , but that’s not what got him to Tax Court.  What got him to Tax Court was the best part time job I have ever heard of. He was hired by Andrew Beer.  Beer was in the investment business and managed to position himself and his company Bricolage into the center of the turn of the millennium tax shelter craze that Jack Townsend referred to as a massive raid on the treasury.

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Court Dismisses Suit Against Government From IRS Search That Led To Suicide

Court Dismisses Suit Against Government From IRS Search That Led To Suicide

The government does not now disagree with the general proposition that a partner is taxed on distributions removed from a partnership only to the extent that the distributions exceed the partner’s adjustedbasis inthepartnership. 26U.S.C. §731(a). In reviewing the written and oral exchanges at trial surrounding this issue, it is apparent that the district court (against all odds, given the manner in which it was argued) also understood this general legal proposition but simply did not agree that the evidence Simon sought to introduce was relevant to demonstrating his adjusted basis in the partnership.

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Don’t Sic IRS On Racist Frat Boys

Don’t Sic IRS On Racist Frat Boys

The Internal Revenue Service has about 90,000 people working for it.  Around 20,000 or so are actual enforcement people.  Those revenue agents and revenue officers are mostly trained as accountants.  They are tasked with collecting over two trillion dollars.  There are signs that they don’t have the resources do that job well enough.  TIGTA recently reported that the collections division which has over eleven million delinquent accounts in its inventory hesitates to take automated collection actions, since they are unable to handle the resulting phone calls.  In hundreds of thousands of cases, they know that alimony deductions do not match the income recorded by the recipients (You can guess which way that usually goes) but they can only investigate a small number of the discrepancies.

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Looks Like No Charitable Deduction For Gifts To Steak And You Know Day

The serious part of the site is what is causing me to issue the emergency tax caution.  There is a charitable component to this.  If you send in a donation they will send an invitation to your partner.  Guys, think real hard before you do that.  They will keep 20% and 80% will go to a charity that is dedicated to raising breast cancer awareness.  That of course sends my BS detector into high gear.

You will probably not be shocked to find out that Steak and ______ Day does not show up on guidestar.org.  Digging a little further in the site you will find that the donation actually goes to, forgive me, I am not making this up, an organization called Coppafeel.  It turns out that Coppafeel actually is a legitimate charitable organization.

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