Most Recent Posts
No Authority For How To Compute Housing Investment Exit Taxes
The parties have not pointed to any regulations, IRS guidance, or case law for their interpretation of this language, and I have found none.
Remember You Are Mortal And Make Your Annual Exclusion Gifts In January
Having lived the much softer life of public accounting, I have come up with a different way of contemplating mortality. I will load Table2010CM (available here) into excel and starting fooling with the numbers.
Tax Court Leaning Harder On The Little Guys In Hobby Loss Cases
The issue is whether Swanson was taking people out on the fishing boat to make a profit or just for the halibut,
Structured Installment Sale Can Be A Great Solution To Liquidity Event Tax
Rising interest rates have brought one technique to the fore that had gone out of favor- the structured installment sale (SIS). For what it is worth, if I had another ship come in this is the technique that I would likely go with.
Missing Tax Court Deadline By A New York Minute
Cases where the problems that lead to late filing of Tax Court petitions have been a staple of this blog and are the source of Reilly’s Seventeenth Law of Tax Planning – “Don’t cut your deadlines close and use the US Mail with proof of mailing.
Employee Retention Credit Schemes Are Symptom Of A Dysfunctional Tax System
Lance Wallach is an expert on abusive tax transactions - in a good way. He warns people about them and then helps the ones who didn't hear his warnings or did not take...
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.
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.
Alternative Tax Thinker Trying The Puerto Rico Gambit
“The Insular Cases have no foundation in the Constitution and rest on racist stereotypes. They deserve no place in our law.”
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.