Most Recent Posts
Susan Crile Paints A Picture Of Tax Court Victory For Artists
As I noted it is rare for Tax Court cases to get much attention outside of the tax world. There was one case where I expected that but was disappointed. It actually had two hobby loss components – airplane remanufacturing and yacht leasing – among a host of other issues. The taxpayer was none other than the great F. Lee Bailey, who had as his attorney, the great F. Lee Bailey. I bemoaned the lack of interest in a post titled F. Lee Bailey Tax Attorney – More Fun Than Anietra Hamper’s Underwear. Anietra Hamper was a TV anchorwoman who thought she should be able to deduct the clothing that she wore on air. She lost because her station’s Woman’s Wardrobe Guidelines indicated that women on the air were supposed to dress like, well CPAs, I suppose. Among the items of clothing that she deducted were some that are, you know, unmentionable. That one went viral, which shows that immature as tax bloggers can be, the mainstream media is even worse.
Will Romney 2016 Be Haunted By Unreleased Tax Returns?
I will probably not vote for Mitt Romney, but I think we could do a lot worse when it comes to who our next President is. After obsessing about the matter for almost a year, I decided that there could not be anything in his unreleased tax returns that disqualified him from being President or reflected poorly on his character. If I were in charge of the tax division of his campaign – and there will likely be one – I would do a data dump going back to at least 1990 the day after he announces. I would call the strategy “Let’s Throw PWC Under The Campaign Bus”, because anything sketchy in the returns would be blamed on the accountants. He could probably gather together a fairly large group of entrepreneurs of both parties who were convinced to participate in sketchy shelters by prominent firms.
Tax Court Judge Appreciates Art More Than Your Average Revenue Agent
Lew’s comment is probably a good segue into another thing that struck me about this case. Note the phrase catalogue raisonnée, which I had to look up. It’s part of Lew’s active vocabulary. Bottom line is that, in general, lawyers have much better educations than accountants. That had me wondering if Judge Lauber’s appreciation for art would show up in his biography. Well, it did. Between his bachelor’s degree from Yale in 1971 and his JD from Yale in 1977, he received an MA in classics from Clare College, Cambridge. That’s not the Cambridge that is forty miles or so east of Worcester with the former seminary for Congregational ministers and the technical college, the town where Margaret Fuller and Thomas Wentworth Higginson grew up. It’s the one in England. Clare College was founded in 1326.
TIGTA Must Disclose More About Investigation Of Possible IRS Release Of Koch Industries Return Information
The trope is that S corporation status when it was created in the sixties was meant to provide relief to “small” businesses
Qualification to be an S corporation, though, is based on who can be a shareholder and how many shareholders there are. It strikes some people as altogether wicked that a large company with few shareholders could use this break meant for little people. If someone has that mindset and they start thinking about who is likely to have executed this perfectly legal, but altogether wicked, strategy the Koch brothers, would likely be on their short list, since they loom rather large in the consciousness of the Left. The Koch brothers play a role for the Left, similar to what our Kenyan born Muslim president, who cannot salute properly and plays too much golf, plays for the Right.
Seventh Circuit Allows Do-over On Tax Court Stipulations For Deceived Taxpayers
Mr. Shamrock and Ms. Bigg had filed a petition with the Tax Court, pro se, disputing a $170,000 notice of deficiency. They hired Grant Niehus to represent them before the IRS and Tax Court. Mr. Niehus represented himself as being a lawyer and a CPA. It turned out that even though he had been to law school, he had not been authorized to practice law since 2009 and he was not a CPA at all.
Mr. Niehus had negotiated stipulations that included an agreement to take only 50% of a $435,751 deduction for real estate losses. After signing the stipulations, Mr. Shamrock and Ms. Bigg learned of the deception. They hired Sheldon Drobny as their representative. Mr. Drobny was a CPA and authorized to practice before the IRS and the Tax Court. Mr. Drobny requested that the stipulation be set aside.
LLC Lease Structure Costs Idaho Charity Property Tax Exemption
Putting on my federal tax hat, which is pretty much my favorite, I would think that was no problem. A single member LLC, unless it elects otherwise, is a disregarded entity. That means that you can freely take things out of it and put things into it without recognizing gain or loss and, for federal income tax purposes, transactions between you and your single member LLC have as much tax significance as transactions between me and my shadow. So the fact that the Youth Ranch was leasing from the LLC for the greater of $25,000 per month or its mortgage payments would be a transaction that could be washed right out of any federal tax significance.
Then they applied for a property tax exemption on the building, which apparently was solely dedicated to charitable use. Oops.
Court Rules Oklahoma ObamaCare Not OK
The IRS ruled that for purposes of the credit it did not matter whether the exchange was run by a state or HHS. The language in the statute, however, reads that the credit applies when someone is “enrolled … through an exchange established by the State”. Following that logic taxpayers in states with HHS exchanges do not qualify for the credit and hence there is no employer mandate.
New York Springs Sales Tax Trap On Passive LLC Members
If the only thing you have to consider is federal income tax, entity choice can still be a fairly complicated matter. This case shows that there are other issues that can sneak up on you that have noting to do with federal income tax. Robert Redford was in the news not long ago about a New York state income tax issue, that probably turned on someone not being aware of how having an S corporation in the chain of ownership affected allocations. Something tells me that when the decision was made to organize Ask 244 as an LLC rather than an S corporation, nobody was thinking about personal liability of members for sales tax.
James Traficant Jr. And The Taxpayer’s Burden
Mr. Traficant’s place in tax history is fairly solid, as the Sixth Circuit decision has been cited dozens of time since it was issued. Most recent was the case of Pitcher v Waldman in which Traficant was cited for the principle that fraud can be inferred from circumstantial evidence. I was surprised that I missed Pitcher v Waldman when it came out in early April since it concerned the ugly breakup of a CPA firm. I was thinking I need to do a late post on it, but it turns out that Joe Kristan covered it quite well.
Nevada High Court OKs Tax That Hits Strip Clubs, Exempts NASCAR And Boxing
The other argument is that because of the various exceptions such as boxing and NASCAR there is a discrimination between adult-oriented entertainment and family-oriented entertainment. It’s worth noting that there is something a little off about a culture that thinks it is OK for children to see people beating up on one another and crashing cars but not, post infancy anyway, female breasts. Nonetheless, maybe the clubs have something of an argument there, since “It is what it is”.
In analyzing the claim, the Court notes that the clubs are not starting off from real solid ground.