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Most Recent Posts

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.

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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.

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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.

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Listen Pete Reilly Has Come Unstuck in Time

Listen Pete Reilly Has Come Unstuck in Time

The Mexican War was her generation’s Vietnam. Only it didn’t last as long. And there wasn’t a draft. And what was probably the worst part for her generation was that the United States won that war. It wasn’t just proto-hippy Henry David Thoreau and his ilk that were against the war

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IRS Lactation Intolerant

IRS Lactation Intolerant

PLR 200941003 was about the deductibility of infant formula as a medical expense. Citing Revenue Ruling 55-261, the service held that the formula was not deductible; the reasoning was that the formula just provided for normal nutrition. I think the ruling is wrong and the basis that they used indicates that they missed the point of the ruling request. The ruling request was on the behalf of not, the presumably well-fed, infant, but rather on behalf of the mother, who as it happens, had had a double mastectomy.

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Last Minute Goal by Taxpayers Makes FLP Hockey a Draw for 2009

Last Minute Goal by Taxpayers Makes FLP Hockey a Draw for 2009

The two IRS wins, Jorgensen and Linton, were, as usual, failures of execution. The entities weren’t respected. Personal bills were paid with partnership funds and partnership expenses were paid with personal funds. In Linton, the documents made it ambiguous as to which came first the funding or the gift. Jorgensen’s son commented that he just couldn’t “get his head around” the idea that the partnership wasn’t just like a bank account.

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Cohan Rules

Cohan Rules

I made the Cohan rule the Prime Directive of Reilly’s Laws of Tax Planning – If you don’t have documentation, at least have a plausible story.

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Those Pesky 1099s

Those Pesky 1099s

I didn’t used to worry about this quite as much until I read the IRS audit manual for auto body repair shops. The writer makes the interesting observation that there might be more money in penalties for failure to withhold from the people you should have sent 1099’s than in disallowing deductions.

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