3paradise
1theleasofus
LillianFaderman
299
Brendan Beehan 360x1000
1defense
1lauber
4confidencegames
2defense
Margaret Fuller4 360x1000
storyparadox3
2confidencegames
Storyparadox1
3albion
6albion
1albion
Learned Hand 360x1000
Thomas Piketty3 360x1000
Stormy Daniels 360x1000
Spottswood William Robinson 360x1000
4albion
James Gould Cozzens 360x1000
Lafayette and Jefferson 360x1000
2gucci
Susie King Taylor 360x1000
AlexRosenberg
399
2theleastofus
499
Thomas Piketty1 360x1000
3defense
2transadentilist
Samuel Johnson 360x1000
2albion
Margaret Fuller3 360x1000
Anthony McCann2 360x1000
Office of Chief Counsel 360x1000
Richard Posner 360x1000
Adam Gopnik 360x1000
Margaret Fuller2 360x1000
3confidencegames
2trap
5albion
Thomas Piketty2 360x1000
Maria Popova 360x1000
9albion
1trap
8albion'
2lafayette
14albion
storyparadox2
lifeinmiddlemarch1
2paradise
1madoff
11albion
Mark V Holmes 360x1000
2falsewitness
1gucci
1confidencegames
6confidencegames
1empireofpain
George F Wil...360x1000
Gilgamesh 360x1000
7albion
1jesusandjohnwayne
Ruth Bader Ginsburg 360x1000
Margaret Fuller 360x1000
George M Cohan and Lerarned Hand 360x1000
lifeinmiddlemarch2
5confidencegames
Maurice B Foley 360x1000
Margaret Fuller1 360x1000
10abion
Margaret Fuller5 360x1000
Anthony McCann1 360x1000
12albion
7confidencegames
1paradide
Susie King Taylor2 360x1000
1lafayette
1falsewitness
3theleastofus
1lookingforthegoodwar
Tad Friend 360x1000
2lookingforthegoodwar
13albion
2jesusandjohnwayne
1transcendentalist
Betty Friedan 360x1000
199
11632
Edmund Burke 360x1000
Margaret Fuller 2 360x1000
Mary Ann Evans 360x1000

Most Recent Posts

SPLC Calls Family Research Council Hate Group – Should IRS Take Action?

SPLC Calls Family Research Council Hate Group – Should IRS Take Action?

The other very broad issue is whether the organization is meeting the definition that makes it exempt.  Is it really educational?  Is it engaging in politics? Is it really a church? You could probably come up with a worse way than having an accountant heavy organization making those determinations, but it might take you a while.
It’s not just because an accounting degree is a terrible education for that purpose.  It’s also a cultural problem.  If you task a group of accountants with collecting $2.5 trillion dollars, do you really expect them to take soft stuff that has only a remote potential for bringing in more money very seriously?

read more
When Planning Never Forget The Alternative Minimum Tax

When Planning Never Forget The Alternative Minimum Tax

Surely you have been keeping track of your AMT basis in your S corporation stock.
Oh.  You rely on your accountant for things like that.  Well, I have to tell you.  Your reliance is misplaced.  If you have had the same accounting firm for all the years that you owned the S corporation and they used a good software package like Pro fx continuously for all those years, there is a chance that the number is available.  If you switched preparers several times and they switched software, the chance that you have a good AMT basis number is pretty remote.

read more
Actuary In Tax Court Beats Northwestern And IRS On Accuracy Of 1099-R

Actuary In Tax Court Beats Northwestern And IRS On Accuracy Of 1099-R

Contrary to respondent’s position, petitioner raised a reasonable dispute regarding the accuracy of the Form 1099-R. Although petitioner points to relatively minor discrepancies in NML’s records, we agree with petitioner that the discrepancies are of such a nature that their cumulative effect, compounded over the extended terms of the policies in question, would likely be significant and could very well alter the dates that the insurance policies lapsed.

read more
We're With The Band – Kind Of

We're With The Band – Kind Of

think trying to get a current deduction for backing their daughter’s music management career was probably a bridge too far.  I would have gone for a more conservative approach that would have likely stood up and assured an ultimate ordinary deduction.  Have the band, itself, organize as an LLC with Sara as one of the managing members. Give the Schlieverts a preferred interest with losses allocated based on positive capital accounts.  There would be no Section 183 issue then.  The passive activity rules would defer any deductions, but that is a lot better than having them entirely blown away.

read more

Organizing Junk Mail Does Not Qualify As Manufacturing

In a modern interconnected economy, distinguishing between “manufacturing” and other activities is silly.
The law’s unwise distinction between “production” activities and other activities encourages taxpayers to try to qualify, and forces the courts to try to draw distinctions.

read more

JD Salinger – Was January 27 2010 A Good Day To Die

Even more fantastic, was there a contingency plan in place in the event that death occurred late in December ?  How hard would it be to post-date a death certificate under those circumstances ?  It makes a good “ripped from the headlines” plot for Law and Order, but the income tax advantages of the step-up in basis are so sweet that it would actually be stupid estate planning.

read more

Was JD Salinger Facing A Major Estate Tax Problem ?

The part of the litigation that would be really interesting to the Agent From Hell is this affidavit by Phyllis Westberg.  She opines that a sequel to Catcher in the Rye written by Salinger would command an advance of at least $5,000,000.  It would seem that the “complete history of the Caulfield family” would qualify as at least equivalent to a sequel.   Throw that in with what may turn out to be the greatest World War II novels ever  and some other stuff and AFH will be arguing that there must be something like $50,000,000 worth of manuscripts in that safe.

read more
Study Shows Taxpayers With Balance Due More Likely To Cheat

Study Shows Taxpayers With Balance Due More Likely To Cheat

Doctor Rees-Jones finds, however, that there is significant bunching near zero balance due and that bunching is more pronounced the higher the income.  I suppose that you could attribute that to just being accurate in estimated payments.  There is more.
The bunching at close to zero balance due is associated with what the Professor calls “income shocks”, the type of income events that are harder to predict

read more