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Most Recent Posts

Time To Eliminate Joint Filing ?

Time To Eliminate Joint Filing ?

The trilemma holds that an income tax cannot simultaneously maintain progressive marginal rates, impose equal taxes on equal-earning couples, and insist on marriage neutrality.

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What Were They Thinking ?

What Were They Thinking ?

One of the ways to buy time is “managing payables”.  In its extreme form you only pay bills to vendors who are capable of and prone to exacting immediate revenge like shutting off the lights.  When operating in this mode there is a great temptation to not deposit payroll withholding. 

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Partnership Needs More Than One Partner

Partnership Needs More Than One Partner

If the deal had otherwise worked it would have been really devastating to lose it on that basis, since an election by the disregarded entities to be treated as corporations would have saved it.  Actually it was just another nail in the coffin, but one to watch out for in transactions of more substance.

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Bill Romanowski's Tax Court Loss Not A Typical Horse Case

Bill Romanowski's Tax Court Loss Not A Typical Horse Case

The bottom line is that both the Romanowski and Pederson are really bad tax shelter cases rather than horse breeding cases.  It strikes me as odd that somebody who was going to promote a tax shelter would uses horses, since the business already has red flags associated with it.  I keep a rough tally in my head of what activities are most likely to win hobby loss cases.  Car racing and Amway do not do well at all.  Horse breeders, on the other hand, frequently win, although the IRS keeps going after them.  Whatever anybody else thinks, I’m not going to count these cases against actual horse breeders.

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Fertility Treatment – Is IRS Heteronormative Or Just Muddled ?

Fertility Treatment – Is IRS Heteronormative Or Just Muddled ?

.the IRS and the Tax Court are operating with a heteronormative, marriage-centric understanding of natural or normal reproduction, what qualifies medical and who makes an appropriate parent. This set of norms drove the IRS and the Tax Court to conclude in Magdalin that a deduction was not permissible—not because of any command in the doctrine, but rather because the taxpayer in that case did not fit the IRS’s and the Tax Court’s understanding of who a proper parent is

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Co-op Owner Wins Casualty Loss Appeal

Co-op Owner Wins Casualty Loss Appeal

I was wondering a little about the case going this far given the relatively small deficiency involved.  According to this story this was being used as a test case for 200 other Castle View owners. Eric Levine, the attorney handling the case indicated that it may have broad implications in the wake of Hurricane Sandy:

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