Betty Friedan 360x1000
Margaret Fuller3 360x1000
1falsewitness
2theleastofus
4albion
Mark V Holmes 360x1000
Office of Chief Counsel 360x1000
7confidencegames
2lookingforthegoodwar
1lauber
5confidencegames
Anthony McCann2 360x1000
Margaret Fuller 360x1000
Ruth Bader Ginsburg 360x1000
lifeinmiddlemarch1
13albion
Stormy Daniels 360x1000
1theleasofus
Lafayette and Jefferson 360x1000
399
1confidencegames
1empireofpain
Storyparadox1
Susie King Taylor2 360x1000
3defense
2gucci
1albion
499
3theleastofus
2albion
9albion
11albion
2transadentilist
11632
Thomas Piketty3 360x1000
1trap
1jesusandjohnwayne
Margaret Fuller5 360x1000
George F Wil...360x1000
storyparadox3
Samuel Johnson 360x1000
Edmund Burke 360x1000
Maurice B Foley 360x1000
Anthony McCann1 360x1000
Learned Hand 360x1000
2defense
AlexRosenberg
Tad Friend 360x1000
10abion
Margaret Fuller4 360x1000
Richard Posner 360x1000
Maria Popova 360x1000
1gucci
1transcendentalist
7albion
Susie King Taylor 360x1000
2trap
3paradise
6confidencegames
LillianFaderman
2confidencegames
199
6albion
4confidencegames
2jesusandjohnwayne
Margaret Fuller 2 360x1000
1lookingforthegoodwar
Spottswood William Robinson 360x1000
George M Cohan and Lerarned Hand 360x1000
1defense
Thomas Piketty1 360x1000
Gilgamesh 360x1000
2falsewitness
Thomas Piketty2 360x1000
storyparadox2
2paradise
Mary Ann Evans 360x1000
Adam Gopnik 360x1000
Brendan Beehan 360x1000
12albion
Margaret Fuller1 360x1000
1lafayette
lifeinmiddlemarch2
3albion
James Gould Cozzens 360x1000
Margaret Fuller2 360x1000
1paradide
1madoff
14albion
5albion
2lafayette
299
8albion'
3confidencegames

Most Recent Posts

Best Tax News Of The Year – Aegis For Dreams Wins Tax Exempt Status

A historically accurate Revolutionary War film hasn’t been made in fifty years (and arguably, ever).  In my view, this was a key element of IRS’ granting the Foundation tax-exempt status:  the film cannot compete against something that doesn’t exist.  The Foundation’s Tax Court case magnifies this longstanding void in our country’s filmography.  Aegis for Dreams fills that void. Charitable status puts the story itself at the forefront, not financial profit considerations.  

read more
Charitable Acknowledgements For Tax Purposes Go Badly Wrong

Charitable Acknowledgements For Tax Purposes Go Badly Wrong

While the risk is primarily for DAF gifts of partnership interests, business interests or minority interests in real estate, it is important for all organizations that sponsor DAFs to use the expanded language in future contemporaneous written acknowledgments. This language is designed to comply with Section 170(f)(8) and Section 170(f)(18) requirements.

read more

The Fine Points Of Claiming Charitable Deductions

One of the things we focused on was making sure that we had good acknowledgements on charitable contributions. If the charity did not include the right language, we followed up with them.  I also coached charities I was involved with on this point.  It was amazing how many did not get it.

read more
An Unusual Tax Court Hobby Loss Opinion

An Unusual Tax Court Hobby Loss Opinion

Code Section 183, which does not actually mention hobbies, was part of the Tax Reform Act of 1969.  The IRS issued regulations in 1972.  Both the Code and the Regulations are virtually unchanged since then, so we have nearly 50 years of relevant case law.

read more
Sixth Circuit Rules Low Income Housing Tax Credit Refusal Rights Are Special

Sixth Circuit Rules Low Income Housing Tax Credit Refusal Rights Are Special

Facilitation of the investor exit after the expiration of the fifteen-year compliance period is, therefore, crucial to the efficacy of the LIHTC program. The mechanism creates an incentive, as discussed, for nonprofits to participate in the program; nonprofits will be less likely to enter a partnership that includes an investor, if doing so entails a serious risk of an ownership battle after the fifteenth year. 

read more
Lessons From Gene Bicknell’s Victory Over Kansas In Domicile Dispute

Lessons From Gene Bicknell’s Victory Over Kansas In Domicile Dispute

It turned out that the questionnaire had been handled by a senior wealth advisor who had a team reconstruct the days from information they had available.  Gene was able to establish that he had not really paid any attention to it and had his assistant sign it.  At trial Gene testified that he didn’t average more than 30 days per year in Kansas in 2005 and 2006.  Friends, family and colleagues corroborated this claim.

read more

Supreme Court Boechler Decision Cuts Some Slack In Tax Court Deadline

Now they can petition late, play the equivalent hearing game, and when the game is up, ask for equitable tolling. Or even better, file late and then decide which card to play. Judge Albert G (“Scholar Al”) Lauber can expect a bushel basketful of cases from rounders, defiers, protesters, wits, wags, and wiseacres, all playing the Boechler gambit, with variations.

read more