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Most Recent Posts

IRS Successfully Attacks Tax Shelter With Hobby Loss Rule

IRS Successfully Attacks Tax Shelter With Hobby Loss Rule

So the lenses were never actually placed in service.  There were basis issues with the way they were financed.  There was no meaningful participation by the Olsens to satisfy the requirements of Section 469.  Other than that Mrs. Lincoln how did you enjoy the play? Well there is also 183 to worry about.

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Conservation Easement Syndicates Outlawyering IRS

Conservation Easement Syndicates Outlawyering IRS

This is not the first time that APA has been used against the IRS in the conservation easement fight.  In the Hewitt decision in the Eleventh Circuit nearly a year ago the court invalidated a regulation interpreting the perpetuity requirement. In the Court’s opinion Treasury had not given sufficient consideration to a comment submitted by the New York Land Conservancy.

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On Tax Writing Rabbit Holes

On Tax Writing Rabbit Holes

I had really cut back not even including a reference to the fact that the 69th was the First Regiment of the Irish Brigade during the Late Unpleasantness which produced another famous chaplain – Father William Corby (He was with the 88th New York).  Father Corby would become president of Notre Dame.  Father Stephen Duncan who reenacts Father Corby told me that the “Fighting Irish” nickname of Notre Dame comes from Father Corby’s service to the Brigade.

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MR. REILLY’S CONUNDRUM

MR. REILLY’S CONUNDRUM

That opinion” is, of course, the hallowed Cohan v. Com’r, 11 B.T.A. 743 (1928), re’d in part 39 F. 2d 540 (2 Cir, 1930).. George M., theatrical legend whose graven image overlooks the cut-rate ticket outlet at 48th & Broadway on this Minor Outlying Island off the Coast of North America, starred in this epic.

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Republican Donor Lane Grigsby Must Repay $576,756 Research Credit Refund

Republican Donor Lane Grigsby Must Repay $576,756 Research Credit Refund

In my view the biggest hazard in public accounting is envy.  Unless you have an odd specialty in order to prosper you must work for and associate with people who are much wealthier than you have any hope of ever becoming.

What inflames the envy is something referred to as the “tyrrany of the billable hour”.  In order to make a living you have to do some work or pay somebody else a reasonable wage to do some work.  One of the escapes from the tyraany is “value billing”.  Research credit consulting is one of those things that can be value billed.  Rather than charge based on how much work you do, you charge a percentage of the tax savings.

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Poor Return Preparation Voids Deduction For African Art

Poor Return Preparation Voids Deduction For African Art

“Malian cultural heritage has for several decades, undergone a massive transfer toward Europe and the United States. Analyzing the phenomenon in its universality, it seems very clearly to be the translation of an unequal relation between poor (weak) and wealthy (powerful) nations. The cultural assets of poor nations are being exported to rich nations. Examples to the contrary do not exist”.

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Mississippi Supreme Court Rules No Sales Tax On Wedding Digital Photo Packages

Mississippi Supreme Court Rules No Sales Tax On Wedding Digital Photo Packages

And the undisputed facts show EKB’s customers did not receive Burton’s photographs in tangible form—they did not receive printed photographs, negatives, or film. Instead, they receive purely digital images. The tangible drive or disk is incidental to the nontaxable photography service being provided, much like the paper on which a lawyer prints a will, which is not subject to sales tax. 

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Fake News In The Tax Arena

Fake News In The Tax Arena

The authors were surprised by the number of stories that dealt with tax-exempt status. Although some of it is accounted for by the “IRS Scandal” that I call Teapartygate, they noted there was more.  Finally there is what they call “old chestnuts” including tax protester theories which now spread on social media..

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Opportunity Zone Ponzi Promoter Sentenced To Four Years

Opportunity Zone Ponzi Promoter Sentenced To Four Years

It is over in the eyes of the law, Joshua Burrell pled guilty to a small subsection of the charges filed against him and is now going to prison due to his own actions. To me, a victim, I have relied on the filings with the court on this case to outline the story. I have learned of a capable and well loved Man who overcame substantial early family trauma and addiction to become a local legend. Only to throw away his achievements and talents due to a toxic combination of delusion and greed.

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