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Most Recent Posts

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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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.

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Review Of “Only The Rich Can Play” By David Wessel

Review Of “Only The Rich Can Play” By David Wessel

OZ has a really fascinating origin story which Mr. Wessel tells in a very engaging manner.  He introduces Sean Parker, who is now my favorite billionaire after Warren Buffett.  We get Parker’s life story from precocious coder who was tracked down by the FBI for his hacking when he was sixteen to founding Napster and on to an early role in Facebook which is apparently the source of his fortune.

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