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Most Recent Posts

Hobby Loss Roundup

Hobby Loss Roundup

Although I fell in love with Section 183 cases because they tend to be such great stories and so amusing, that will not be the focus of my seminar. My study of the case law and detailed analysis of over 300 cases has caused me to conclude that key elements of the section are misunderstood by many practitioners (and the public which pretty much goes without saying) and that practitioners tend to be too conservative in counseling clients. The focus of my seminar will be coaching clients and winning audits.

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District Court Tosses Interesting Likely Frivolous Tax Argument Out On Standing

District Court Tosses Interesting Likely Frivolous Tax Argument Out On Standing

The uniformity rule also applies to “incorporated territories”.  As most people see it, there is not much in the way of incorporated territory since Alaska and Hawaii became states in 1959.  There is some. 4.6 acres with no permanent residents – Palmyra Atoll.  Brian sees it differently.  He thinks Puerto Rico is an incorporated territory because it is clearly on the road to statehood.

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Year 15 Low Income Housing Tax Credit Fight Turns Ugly For CohnReznick

Year 15 Low Income Housing Tax Credit Fight Turns Ugly For CohnReznick

The regulations under 704(b) have a concept called “minimum gain”.  Minimum gain places a limit on the amount of losses that can be allocated to a limited partner beyond their contribution, simplistically that is how far negative their capital account can go.  If you want to dig into the details and explanations of CohnReznick’s computations they are available here in exhibits in the Mass Superior Court litigation.  It is hard to see how liabilities could have been counted as going into minimum gain, but have them still hanging after disposition of the property.

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Plan On Having The Death Tax Live On

Firms like Withersworldwide devise plans, draft documents and see that the documents are properly executed and store them.  Then they will review and revise the plan based on changes in the laws or changes in the circumstances of the family they are planning.  The actual execution of the plan falls to trustees, family offices, the family members themselves and my people – accountants.

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Trump Indictment – 34 Counts Of Falsifying – What Is The Other Crime?

Here is the tax thing about legal expense. Is a legal expense deductible ? Well it depends. Until 2021 Trumps return was done by a firm called Mazars.  Mazars is rated number 30 in Accounting Today’s latest top 100.  I am going to go out on a limb and speculate that Trump was the most famous client of Mazars.  So the team doing the return is probably not a bunch of people who just fell off the turnip truck. If I was the TO CFO and I was looking to bury this expense so it would be deducted without question the last account I would have it be paid out of is Trump’s personal account.  That is the account which seems most likely to include nondeductible legal expenses.

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Third Circuit Upholds Tax Court In Large Dollar Horse Hobby Loss Opinion

Third Circuit Upholds Tax Court In Large Dollar Horse Hobby Loss Opinion

He mentioned the Dreicer decision which is actually a sort of hilarious story of a trustifarian touring the world in search of the perfect steak.  Dreicer lost in Tax Court and appealed to the DC Circuit (he was an expat).  The Tax Court judge had indicated that it was not reasonable to expect a profit from the activity.  The DC Circuit sent the case back to the Tax Court indicating that that was not the correct standards.  What you have to have is the objective of making a profit, not the expectation.  Back at the Tax Court again Dreicer still lost, but I give him credit for inspiring Reilly’s Eighteenth Law of Tax Planning – Honest objective trumps realistic expectation

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Kent Hovind’s Third Wife Sues Over Financial Commitments

Kent Hovind’s Third Wife Sues Over Financial Commitments

The new DAL is much more conventional in structure. The property is owned and operated by Creation Science Ministries Inc a 501(c)(3) organization that is recognized by the IRS as a church. A for profit S Corporation owned by Ernie Land, Kent’s consigliere of a sort, runs the store and pays Kent for the use of his intellectual property. Mary Tocco, Kent’s second wife, maintains that the new DAL in practice runs much as the old one did with no actual accountability on Kent’s part.

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