Most Recent Posts

Don’t Complain To IRS If They Are Slow To Process Your Fraudulent Refund Claim
Joe slipped up on controlling the mail one day in October 2010 and learned about the liabilities from IRS mail. When she pressed Joe for answers on why the liabilities are so high, he slammed her against the wall. After he went to sleep that night, she hid his gun being afraid that he might use it.

The Fine Points Of Claiming Charitable Deductions
One of the things we focused on was making sure that we had good acknowledgements on charitable contributions. If the charity did not include the right language, we followed up with them. I also coached charities I was involved with on this point. It was amazing how many did not get it.

An Unusual Tax Court Hobby Loss Opinion
Code Section 183, which does not actually mention hobbies, was part of the Tax Reform Act of 1969. The IRS issued regulations in 1972. Both the Code and the Regulations are virtually unchanged since then, so we have nearly 50 years of relevant case law.

Sixth Circuit Rules Low Income Housing Tax Credit Refusal Rights Are Special
Facilitation of the investor exit after the expiration of the fifteen-year compliance period is, therefore, crucial to the efficacy of the LIHTC program. The mechanism creates an incentive, as discussed, for nonprofits to participate in the program; nonprofits will be less likely to enter a partnership that includes an investor, if doing so entails a serious risk of an ownership battle after the fifteenth year.

Lessons From Gene Bicknell’s Victory Over Kansas In Domicile Dispute
It turned out that the questionnaire had been handled by a senior wealth advisor who had a team reconstruct the days from information they had available. Gene was able to establish that he had not really paid any attention to it and had his assistant sign it. At trial Gene testified that he didn’t average more than 30 days per year in Kansas in 2005 and 2006. Friends, family and colleagues corroborated this claim.

Supreme Court Boechler Decision Cuts Some Slack In Tax Court Deadline
Now they can petition late, play the equivalent hearing game, and when the game is up, ask for equitable tolling. Or even better, file late and then decide which card to play. Judge Albert G (“Scholar Al”) Lauber can expect a bushel basketful of cases from rounders, defiers, protesters, wits, wags, and wiseacres, all playing the Boechler gambit, with variations.

Delaware Chancery Refuses To Apply Ferengi Principles To Low Income Housing Deals
Because the partners understand and intend the Property Partnership Interests will terminate with a ROFR disposition, it seems to me that an improperly exercised ROFR does not change the value of the Fund’s Property Partnership Interests, and so cannot constitute a material adverse event on the Fund.

ABLE Accounts For Disabled Have Many Advantages And Should Be Better Known
The most thorough convenient source for information about ABLE is the website of the ABLE National Resource Center, a collaborative managed by the National Disability Institute. A valuable feature is one that allows you to compare the programs of different of states.

Review Of “Only The Rich Can Play” By David Wessel
OZ has a really fascinating origin story which Mr. Wessel tells in a very engaging manner. He introduces Sean Parker, who is now my favorite billionaire after Warren Buffett. We get Parker’s life story from precocious coder who was tracked down by the FBI for his hacking when he was sixteen to founding Napster and on to an early role in Facebook which is apparently the source of his fortune.

Low Income Housing Tax Credit Year 15 Roundup
On the NFP side, there is an expectation that through the exercise of a right of first refusal the not for profit sponsor will achieve ownership of the property to insure its long term affordability. Investors, often referred to as aggregators, strive to get a serious payout or retain ownership after Year 15.