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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.

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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.

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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. 

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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.

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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.

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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.

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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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