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

Most Recent Posts

Tax Court Crafts Ultimate Pick Up Line

Tax Court Crafts Ultimate Pick Up Line

At any rate the Tax Court went along with the IRS on this one. It boils down to his exempt purpose not benefiting a broad enough class of people. The petitioner claimed it was a very broad class indeed namely all women in the world capable of bearing children. The tax court thought the class somewhat more limited – namely women who want to bear his children.

read more
Just Because They Won’t Let You Do it Doesn’t Make it a Good Idea

Just Because They Won’t Let You Do it Doesn’t Make it a Good Idea

If a couple chooses to use any of these techniques, the most likely way they would fail on audit is through poor execution. Everything must be done in the same way as it would be done in a truly arms-length transaction. If there is a note for a property sale a mortgage should be recorded. Payments should be made regularly as defined by the terms of the contract.

read more
Windfall For “Unmarried’ Couples

Windfall For “Unmarried’ Couples

CCA 201021050 may provide a significant windfall for some unmarried couples.  It is directed toward registered domestic partners in California and some commentators indicate that it is logically applicable to California same-sex married couples.  The ruling emphasizes the point that state law determines the ownership of property and that the taxation of income follows the ownership of that income. 

read more
Breaking Up is Hard to Do

Breaking Up is Hard to Do

There used to be a joke that there are three ways to get out of a burned-out tax shelter. The first was to put the interest into a defective grantor trust and then cure the defect. It was a really neat idea. It doesn’t actually work, but it was clever. Then there was dying. Pretty drastic, but it worked (until this year anyway). Finally, there is giving it to your spouse and getting a divorce. Still works.

read more
The Magic of S Corporations – Tax Alchemy in Reverse

The Magic of S Corporations – Tax Alchemy in Reverse

There are two observations to be made here. The first is that it is possible that LLC’s would have better served their purposes. The unified basis of partnership interests would likely have prevented this odd result. The other is that just a little bit of paperwork might have also saved the day. If the S corporation loans had had written evidence of indebtedness then the repayment would have been a capital gain.

read more
Sometimes You Should Just Pay The Taxes

Sometimes You Should Just Pay The Taxes

The moral is that tax savings are money. If buying something allows you to save taxes then the thing that you buy doesn’t cost you as much. It doesn’t make it free. And it is possible that, even with the discount that the tax savings create the thing is not worth what you are paying for it. I might go so far as to speculate that if the thing is designed with tax savings in mind that the designer feels entitled to a goodly share of your tax savings. In some cases, it might be your tax savings and then some. In which case, as the title says, it would be better to have just paid the taxes.

read more
Steve Martin – Tax Advisor

Steve Martin – Tax Advisor

We find “Taxpayer A represents that he suffers from a condition which impairs his memory.” There it is. “I forgot.” Whether the memory issues having anything to do with the gender transformation between the head note and the third paragraph is a question left unanswered.

read more
Saint Patrick’s Day in May

Saint Patrick’s Day in May

James is still processing the experience. He wants to cultivate a spirit of detached generosity. On the other hand he wants to share his joy in the whole experience. It is just possible that he saved Sammy’s life. He is hoping Sammy doesn’t screw up agian, but – I don’t know.

read more
Let’s Be Counted Early and Often

Let’s Be Counted Early and Often

I immediately was thinking about finding a bunch of homeless guys to stay over so that what the genealogy bug bights some future descendant, they can be utterly confused by the 2010 census that includes me.

read more