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Most Recent Posts

You And Your Shadow Do Not A Partnership Make

You And Your Shadow Do Not A Partnership Make

The key to Son-of-Boss was a paired currency option.  When you contribute the paired option to the partnership you don’t treat your obligation to perform on one side as a liability, but you claim corresponding basis on the other side anyway.  Essentially you have an unbalance entry, which is why normal accountants have such a hard time understanding the deals.  Anyway without a partnership, you can’t even pretend that the whole things work.

I don’t think it is news that you can’t create a partnership with yourself and a disregarded entity, but it is a point that bears repeating.  You can see it  happening in the family limited partnership space.  I haven’t thought through whether that would be fatal to discounts, but the notion makes me very uncomfortable

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Tom Brady’s MVP Truck Even More On The Tax Implications

According to Forbes (And how could you do better?) Tom Brady gets about $7 million a year in endorsement income.  Like I have said my knowledge of sports is subpar for an American male, but there is one thing that I have picked up.  Part of Tom Brady’s image, or you might say his brand, is that he is a “There is no I in team” type of guy.  

I was way too preoccupied with the repair regs and Kent Hovind to pay much attention to Deflategate, but I don’t think that it could have helped the Brady brand.  So this class act with the truck might have been just the uptick his image needed.  That’s the story I would have ready for AFH.  Passing up that Chevy truck for a teammate was a shrewd move to keep the endorsements coming.  But there is more.

Maybe Tom Brady is still loyal to the Dodge Dart and showing up at Chevy dealership, even to pick up a free truck, would be an embarrassment.

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Good Execution Protects Sellers From IRS Transferee Liability

Good Execution Protects Sellers From IRS Transferee Liability

The GNC shareholders had been paid with outside money.  They had made reasonable inquiries to determine that Midcoast was a legitimate company.  They were perfectly happy to remain innocent of the secret sauce that made it all make sense for Midcoast.  Whatever monkeying around was done after they were no longer shareholders – well – Not their circus, not their monkeys.

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Islamic Teaching On Usury Kills Property Tax Exemption In Tennessee

In Maryland, which has a Catholic pedigree if you go back far enough (There is a reason that they call it the Baltimore catechism)  an apartment complex housing married couples serving as temple “ordinance workers”  for the Church of Latter Day Saints was exempted as a “convent”.  Similar status was sought and won by a pagan Phryganium in a pretty bitter struggle with assessors in Catskill, NY.

In the case of the Islamic Center of Nashville, we have an arrangement that was, in substance under general tax principles, a mortgage.  If religious scruples did not prevent the calling of a spade a spade, ICN’s property tax exemption would not have been disturbed at all.  Every other religion I can think of can take out a mortgage without disturbing is property tax exemption.  It will be interesting if this is appealed and feeds into the debate about importing Sharia law into judicial decisions.

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Kent Hovind Supporters Gaining Ground

Pete called the office of Judge Margaret Casey Rodgers, who sentenced Kent eight years ago and is scheduled to preside over the upcoming trial.   I have to tell you when it comes to Hovindicators and Judge Rodgers, don’t get them started.  Steve Quayle has also picked up the story.

Rudy has gone so far as to announce that they own the internet.   The great white whale of Rudy’s media campaign is Alex Jones Info Wars.  Rudy has taken to calling their tip line every morning and has begun to think that Info Wars lack of attention to the matter may be a sign that Alex Jones is actually controlled opposition.

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Lois Lerner’s Old IRS Team Looking Anti-tech

Lois Lerner’s Old IRS Team Looking Anti-tech

Last I checked there was no declaration of war in effect, so what are these “governments of nations whom are our enemies” and I may be crazy, but I think as the world gets smaller and smaller we need to think of it as a community, but that’s just me maybe.

Back in September I wrote about a pair ruling in which the EO group turned down a sorority that met on-line for 501(c)(7) status and an organization that provided free wi-fi for 501(c)(3) status.  I attributed both those rulings to meatspace prejudice, but now I’m thinking there might be a full blown Luddite cult operating in there.  We’ll see.

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