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Most Recent Posts

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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Low Income Housing Tax Credit Year 15 Roundup

On the NFP side, there is an expectation that through the exercise of a right of first refusal the not for profit sponsor will achieve ownership of the property to insure its long term affordability. Investors, often referred to as aggregators, strive to get a serious payout or retain ownership after Year 15.

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Independent Economy Council Reports Many 1099 Workers Troubled By Tax Obligations

Independent Economy Council Reports Many 1099 Workers Troubled By Tax Obligations

If an independent worker is somebody who earns money from working without getting a W-2 you could conceivably include partners in all sorts of professional firms, Donald Trump, Stormy Daniels and me. I bring up Stormy Daniels, because I covered a story on Stormy protesting a California law that might make it harder to classify, you know, entertainers as independent contractors when they worked in certain sorts of venues.

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Watch That Last Minute Joint Return For Final Year Of Marriage

Watch That Last Minute Joint Return For Final Year Of Marriage

We really need to remember that when we are preparing a joint return that we have two clients.  Particularly when it comes to the final joint return, we need to recognize that their interests might not be aligned.  Make sure that both parties are aware of the implications of joint and several liability.  And that joint filing is an election – not a marital vow.

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