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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.  

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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.

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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.

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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.

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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. 

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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.

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