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Most Recent Posts

New York Toys With Out Of State Partner

New York Toys With Out Of State Partner

If a 754 election had been in effect, there would have been a lower flow-through of gain from the partnership and a modest or no gain or loss on liquidation.  The lack of the inside-basis might have minimal effect on federal tax due, since the capital loss on liquidation of the partnership would offset the flow-through gain.  There likely would have been no state income tax effect either, if Mr. Olsheim had lived in New York.  The capital loss would be included in the computation of his New York state income tax.

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Bank Cannot Issue 1099-C And Subsequently Try To Collect

Bank Cannot Issue 1099-C And Subsequently Try To Collect

If this ruling stands, financial institutions will be encouraged to delay having an identifiable event as long as there is the dimmest hope that something might be collected.  1099-C when finally issued will be a blast from the past to the recipient, who if they are diligent will probably be able to come up with an argument that the debt expired in a much earlier year.

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Hipster Tax Has Historical Precedent

Alpha children wear grey. They work much harder than we do, because they’re so frightfully clever. I’m really awfully glad I’m a Beta, because I don’t work so hard. And then we are much better than the Gammas and Deltas. Gammas are stupid. They all wear green, and Delta children wear khaki. Oh no, I don’t want to play with Delta children. And Epsilons are still worse.

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IRS And 501(c)(4) Damned If They Do Damned If They Don’t

IRS And 501(c)(4) Damned If They Do Damned If They Don’t

We have seen how much trouble the IRS has had just with applications for exemption.  To really enforce the law, they will have to audit organizations like American Action Network to determine if maybe some of that media placement actually had something to do with campaigns.  The process would end up being like smoothing the air bubbles when hanging wall paper.  A tainted 501(c)(4) would shut down and a new one will pop up.  Apparently these things don’t require much infrastructure.  According to the 990, less than 2% of AAN’s expense are for management and fundraising.  That would be outstanding, if it were a charity.

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Doctor Dino Denting Deficit ?

Doctor Dino Denting Deficit ?

I tend to think that the ways in which people are screwed up is related to us evolving over a million years to live in small hunter gather bands and our genomes have not had time to catch up with agriculture and civilization in general.  Frankly, though, original sin probably works as well to account for how we are and is simpler to understand.

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Leisure Suit Larry Shows Up In Tax Court Decision

Leisure Suit Larry Shows Up In Tax Court Decision

I can imagine one of them telling me the story “You wouldn’t believe it, Pete.  This guy comes in and he tells me that he is going to make a video game.”  I reply that that is getting to be a big business now.  I know this because my buddy Mikey and I always go to the Dream Machine and drop quarters into Spy Hunter on our dinner breaks during tax season.
“I know, I know, but listen to what the game is about.  It’s about a forty-year-old guy going to discos and not getting laid.”  I agree that it seems kind of stupid.  Too much like real life.  “It gets even better, though. He thinks that in the long run, he’ll be making training simulators for the FBI and groups like that.”  Now that is really crazy.  Lots of guys in the FBI come from Jesuit Colleges.  They learned how not to get laid in Catholic grammar school, they don’t need a computer program for that.  “No. No.  The FBI stuff is from a submarine game.”  The FBI has submarines? “Anyway, I told the guy we were kind of busy and probably couldn’t help him”.
Accountants actually do provide value to entrepreneurs, but many of us are lacking in “the vision thing”.  It is not reasonable to chide someone who has succeeded in improbable ventures for not asking “experts” whether a business scheme is feasible or not.

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Billy Sol Estes – Better To Owe It To You Than Cheat You Out Of It

Billy Sol Estes – Better To Owe It To You Than Cheat You Out Of It

  If I sell you the Brooklyn Bridge that creates immediate income.  If I can convince you to loan me money using my interest in the Brooklyn Bridge as security and the transaction is recognized as a loan, that is not immediate income.  Someday, I may have to pay the piper if I finally stiff you, but there are ways around discharge of indebtedness income, like bankruptcy, for example.  That is why it is better to owe it to you, than cheat you out of it.

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