Most Recent Posts
Fourth Circuit Holds Former Shareholders Not Liable For Corporate Tax In Midcoast Deal
Originally published on Forbes.com on June 9th, 2012 When the Tax Reform Act of 1986 was enacted, I was all over that thing. One thing that was crystal clear to me was...
Tax Court Rules 1099-C From Portfolio Recovery Associates Not Valid For Year Issued
I always like it when I can unreservedly cheer a taxpayer win. The Tax Court decision in favor of David and Carla Stewart makes me feel that way. There are certain tax...
Sixty Four Dollar Question – Eleventh Circuit Rules IRS Can Charge Preparers For ID Numbers
Originally published on Forbes.com on June 9th, 2012 I kind of admire Jesse E. Brannen, III, although I have to say he could have found a better use for his time and...
Federal Circuit Finds Statute Circular – Invalidates Regulation
It's really too bad. I cannot figure out a way to make the Federal Circuit decision in Dominion Resources interesting to a normal person, but I feel compelled to write...
Does Sallie Mae Want Students To Default ?
For lenders who only lend to students (and don’t guaranty, or collect on defaulted loans), they lose no money on a default. The money they are reimbursed can (and is) immediately used to fund another loan. Therefore, these lenders, fiscally, have a neutral outlook about defaults (i.e. they don’t care one way or another if a loan defaults).
If a company both loans, and also owns collection subsidiaries, then as long as collection of defaulted student loans is profitable (and it is extremely profitable), then this company clearly and unambiguously has a financial interest that loans default rather than remain in good stead.
Tax Protesters Rack Up Another “Victory”
Originally published on Forbes.com on June 5th, 2012 It is hard being a tax protester. Coming up with crackpot theories and having them slapped down by the IRS and the...
After Twenty Years Congress Still Has Not Acted On Sales Tax
Annette Nellen is a professor at San Jose State University. She has an excellent blog on tax policy called 21st Century Taxation. Professor Nellen was selected by the...
CPAs Face Challenge In Early Stage Of Zombie Apocalypse
In my posts on some of the tax proposals, I have expressed concern about lack of Zombie apocalypse awareness evident in some proposals. My biggest concern is...
Marriage Equality Victory On DOMA In First Circuit – Same Sex Couples Need To Watch Statute Of Limitations
The First Circuit, upholding, a lower court decision, has ruled that Section 3 of the Defense of Marriage Act is unconstitutional. Section 3 of DOMA provides that...
Couple Denied Homebuyer’s Credit – You Are Not Your S Corporation And Your S Corporation Is Not You
Jack and Joan Trugman owned several pieces of rental real estate in Texas, Missouri and California in their S corporation (Santsu Corporation). S corporations are...