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Most Recent Posts

No Fans Of Sister Wives At The IRS ?

No Fans Of Sister Wives At The IRS ?

These beliefs and practices include polygamy or plurality of wives. You stated that you “…have a religious belief known as ‘Celestial Marriage’ which includes a plurality of wives.” You describe “Celestial Marriage” as a private religious relationship between consenting parties of legal age which is not recognized as a marriage by state authorities.

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Carried Interest Debate Heats Up Without Much Light

Carried Interest Debate Heats Up Without Much Light

If, however, the Administration really thinks venture capitalists and the like should not be getting capital gains treatment, there may be a fix that does not require another three thousand words in the Code and the cooperation of Congress.  Just have the IRS rule that operating investment pools as partnerships so that managers can receive their compensation in the form of a share of the partnership’s capital gain is not consistent with the intent of Subchapter K.  Those arrangements could be operated as co-ownerships that pay a management company incentive compensation.

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Ellen DeGeneres Speaks Out For Spanish-American War Widowers

Ellen DeGeneres Speaks Out For Spanish-American War Widowers

You would think with all the talk about the 1,138 rights there would be a list somewhere.  Well, if I was more of a geek, I would make one for you.  What you have to do is take this report from 1997 and update it with this report from 2004, which lists things that were either  repealed or added. 

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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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