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Most Recent Posts

Tea Party Patriots Inc Dodging Tax On E-mail Fees?

Of course, I just have the same education as an IRS revenue agent, so maybe there is something in the definitions that would exempt this or possibly TPP has enough other social welfare activity that it would still qualify.  Regardless, I think there might be just a bit of concern about its 501(c)(4) status.

Since TPP does not appear to be a dark money group, I kind of wondered why the status was so important.  Well, now, given the e-mail fees, there could be some serious money at stake.  The best defense is a good offense.  The persecution narrative might be a license to be aggressive.

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IRS Will Not Tax Forfeited Jackpots Of Compulsive Gamblers

IRS Will Not Tax Forfeited Jackpots Of Compulsive Gamblers

Well, in the interest of fighting gambling addiction, I offer this.  The ruling was only on the program in one state and I don’t know which one.  The program seems to be similar from state to state, but it is not identical.  Subtle differences might make for different income tax answers.  For example, the Indiana program indicates the forfeiture is in the “form of a fine”.  In the Illinois program, the participant gets to decide which of the addiction services organizations the money goes to.  So it might still be possible that in your state there would be a difference that would make you taxable on the forfeited jackpot.  So stay out of those casinos.

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Bank Out 40 Grand When It Allows Withdrawal Two Hours After IRS Levy

Back before Congress put significant restraints on IRS collection activities in the mid-nineties, I remember a period when they tried automating the collection process.  It could be extremely painful as money was grabbed from people who did not really owe it.  As I read collection due process cases, it strikes me that we may have gone a bit too far in the other direction as taxpayers seem to be able to stretch the process interminably.  I don’t see a lot of jeopardy assessments, but it appears that banks are going to be under pressure now to act on them very quickly.  You have to wonder how this case would have turned out if Mr. Hanson had beaten Mr. Waterman to the bank by two minutes instead of two hours.  Clearly, though Chase had to respond much more quickly than two days.

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Do You Need To Maximize Rents To Claim Rental Losses?

Do You Need To Maximize Rents To Claim Rental Losses?

Even if petitioner did not reside at the Lemoore property, we still find that he used the property for personal purposes because he rented the dwelling for less than fair rental value. Petitioner stated that he based the amount of rent on what Ms. Corfman could pay rather than on the fair rental value rates for comparable properties in the Lemoore, California, area.

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Home Sweet RV Does Not Always Produce Best Tax Result

Home Sweet RV Does Not Always Produce Best Tax Result

Although I understand the Tax Court and IRS reasoning, to be totally honest, I think that I might have blown this one.  You are driving your RV to the RV rallies to sell RV insurance.  Seems logical to me.  If I had done their return, I would have been in Tax Court falling on my sword to save my clients eight grand.

The other evil thought that crossed my mind is that if the Jacksons had taken the kitchen out of their RV, that might have taken it out of the definition of “dwelling unit” –  ” the term “dwelling unit” includes a house, apartment, condominium, mobile home, boat, or similar property, which provides basic living accommodations such as sleeping space, toilet, and cooking facilities”.   Don’t know if that would have worked, but it would have made an interesting discussion.

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Where Tax Shelters Go When They Die

Where Tax Shelters Go When They Die

At any rate there have to be some basic economic factors that prevent developers from slapping some signs up on a grassy field that call it a cemetery and having its valuation go up by a couple of orders of magnitude.

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Tax Court Omits Key Sentence In Ruling Against Taxpayer

Tax Court Omits Key Sentence In Ruling Against Taxpayer

The case involved the activity grouping rules of Code Section 469, the silver bullet of the Tax Reform Act of 1986, which was supposed to end all tax shelters forever.  When it comes to the activity grouping rules, there are three types of tax practitioners: those who are, at most, vaguely aware of them; those who have studied them intently and remain somewhat bewildered; those who claim to understand them.  The third group can be divided between people who have deluded themselves and liars.

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Robert Redford’s New York Tax Trouble Provides Lessons For Planners

Most states follow federal principles pretty closely in computing state taxable income but note well the caveats in that statement.  “Most states” and “pretty closely”.  It probably came as a very unpleasant surprise that inserting an S corporation into the chain of tiered entities can make a big difference in New York state’s view of the transaction, but there you have it

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The OID Fraud And Criminal Gullibility

The OID Fraud And Criminal Gullibility

I have to say that I have some sympathy with the perspective that a reasonable person seeing the refund checks might want to take another look at the scheme.  If they were incapable of understanding the reasoning behind the scheme and what OID actually is, it could be hard to resist.  Something tells me that it might be people other than Ms. Rampton, who really belong in federal prison and that she is, herself, a victim of this scheme.

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