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Most Recent Posts

Mr. Koskinen’s Last Chance To End The Form 3115 Madness

Mr. Koskinen’s Last Chance To End The Form 3115 Madness

I did a short survey to an extremely small unscientific sample of tax preparers asking if they expected to do one of more Forms 3115 for virtually every trade or business client.  It’s running about half. As it stands now, I’m leaning toward the tree killing side, but I don’t have many returns to do and they almost all extend, so I can pretty much wait and see.  I suspect that the people who are saying this is overblown will turn out to be right.  It will be like those blurbs we put on our emails that we thought were required by Circular 230, but why take the risk.  So realistically, if the IRS does not take action to stem the flow Ogden will only be hit with 5 or 6 million pointless forms, since there are people more courageous than me who will not be intimidated and people more clueless than me, who will miss the whole drama.

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Oil Rig Manager Does Not Qualify As Foreign Resident

Oil Rig Manager Does Not Qualify As Foreign Resident

Petitioner’s ties to Louisiana during 2007-2010 were at least as strong as, if not stronger than, those of the taxpayer in Lemay. Throughout this period petitioner owned a house in West Monroe that he had built. While he was overseas his first wife, his second wife, and his daughter lived in this house or in his parents’ house, also in West Monroe. During his off-duty periods petitioner regularly returned to West Monroe for an average of 23 days per period to be with his  family. His business affairs were generally handled by his mother, whose address in West Monroe he used as his mailing address. His driver’s license, voter registration, bank accounts, and motor vehicles were all centered in Louisiana. His ties to Sakhalin Island, by contrast, were entirely transitory and did not extend much beyond the bare minimum required to perform his duties there

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Repair Regs And Tax Pros Are Like Headlights And Deer

Repair Regs And Tax Pros Are Like Headlights And Deer

The regulations totally refer to the physicality of the building and except for some de minimus  rules make no reference to dollars.  The regs say that if you have 10 roof mounted HVAC units and you replace three of them, you can expense that.  CSG takes that and makes the logical leap that if you have carved out $100,000 of the original building cost to HVAC and you have a bill for less than $30,000 you can expense it, more than $40,000 you have to capitalize with a gray area in between.  At any rate that is what I understood the rep to have presented.  I voiced my objection to that not reflecting what the regulations said and he indicated that might be true, but what else can you do and, of course, their IRS insiders had given the nod to this reasoning.

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Don’t Use The IRS To Address Koch Political Spending

Don’t Use The IRS To Address Koch Political Spending

In the end the concern about dark money is an ad hominem argument.  I’d like to think that we are smart enough to look at the merits of ideas without knowing who is pushing them.  Of course from here on in, progressives will be able to use the lack of transparency to attribute any support received by their opponents to the Koch brothers.  Play it that way and let the IRS stick to collecting taxes.

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