Most Recent Posts
IRS Attorney Advises Agents Not To Be Intimidated By No Trespassing Signs
The IRS has a fairly ferocious reputation in some circles. Personally, I think the Service's ferocity is somewhat exaggerated. Consider, for example, PMTA 2012-003 . If...
Wandering Tax Pro On The Tax Aspects Of Divorce
We had about the softest winter I have ever experienced in New England this year, but it is till nice to look around and see the signs of Spring. If you follow tax...
Family Limited Partnership Needs To Have Partners – Plural
Originally published on Forbes.com on May 9th, 2012 Estate of Lois L. Lockett, et al. v. Commissioner, TC Memo 2012-123 One of the most fundamental principles of...
President Obama Being For Marriage Equality Does Not Make Marriage An Unqualified Good Deal
Originally published on forbes.com. President Obama has come out in favor of marriage equality, which seems to be generating quite a bit of excitement. As far as I can...
Donating TriBeCa Facade Easement Is Like Renouncing Your Super Powers
If the Cobblestone owners tried to mess with their building facade, there would be plenty of people in the neighborhood who would rat them out to the Landmark Preservations Commission for free. They don’t need people flying up from Washington to do it.
The case has almost exactly the same facts as 1982 East LLC which was another Manhattan historic facade donated to NAT that had no value due to already existing restrictions. Somewhat more entertaining were Boltar LLC where the appraiser came up with a hypothetical development that would not fit on the property and Esgar Corporation which involved a fantasy gravel mine.
Divorce Lawyers – Frequently Not The Best Tax Advisors
Originally published on Forbes.com on May 6th, 2012 You can get bad tax advice or no tax advice in just about any area of life, but from my reading of tax cases and...
Conversion Of “Rental Property” To Personal Use Does Not Blow 1031 Like Kind Exchange
Originally published on forbes.com. If you want your exchange to qualify for deferral under 1031, it is not enough that the properties be of like kind. (With real...
Dell Not Subject To Damage Claim For Collecting Too Much Sales Tax
Sometimes, it is not nearly as much fun to be a major corporation as those Occupy Wall Street folks seem to think. Take sales tax for example. The states are all over...
Could Refinancing All Student Loans Be A Free Lunch For The Taxpayers?
As I noted, the consolidation program outlined above worries them a little. Well, here is what I am thinking. Maybe we the taxpayers need to encourage our President and his likely opponent to propose a program that would worry Sallie a lot. It is our guaranty that makes the debts of those kids (and many of them are not kids anymore) a valuable financial asset, that the capital markets can play with for the next 20 years. Why don’t we just offer to refinance the whole lot at a reasonable rate? That includes the loans that are not performing that well. We are already stuck with the downside on them because of the guaranty. If we want to be nice guys, we could do things like put in bankruptcy protection for the really desperate. But even, if we want to be hardnosed about, it is the taxpayers who are at risk that should be making the profits on the loans for the next twenty years.
Beating The Possible Estate Tax Increase Without Switching To Cat Food – The Midmill Dilemma
The Problem The current scheduled changes in the estate and gift tax rates and exemptions have me struggling to come up with some good ideas for a particular class of...