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Most Recent Posts

Guess me Out of the Ballpark

Guess me Out of the Ballpark

Most people don’t keep very good track of how they spend their time. The regulations do not specify a particular method, but the cases beginning with William Goshorn in 1993 (TCM 1993-578) seem to characterize any method that taxpayers use to reconstruct their time as being a “post-event ballpark guesstimate”. “Ballpark guesstimate” which seems to me to be a fairly robust concept is apparently limited to estimates of time spent to satisfy material participation requirements.

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It Doesn’t Have to Be a Good Idea

It Doesn’t Have to Be a Good Idea

For example, if someone’s investment in a stock or a business were based on Feng Shui or some other cultural judgment, that would not per se be “irrational”. Petitioners used their best judgment and successfully tested their business approach. Ultimately, the fact that their approach was unsuccessful does not make it irrational.

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Investment Interest Relief

Investment Interest Relief

If you invest on margin or otherwise have investment interest ( You may, for example, have received a debt-financed distribution from a partnership which you deposited into your brokerage account), take a look and see if your return has Form 4952 attached. On Part III Line 7, there may be a number showing your carryover of investment interest. If that number is a NUMBER, you may want to discuss with your preparer whether you might benefit from the election in the future. If it is REALLY A NUMBER, it may be worth amending even if you have to request permission for a late amendment.

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Threat to Parsonage Exclusion

Threat to Parsonage Exclusion

One big difference between the military housing allowance and parsonage is that it is set by statute and is thereby limited. More importantly, except for some really far out militia types, nobody can have much objection to the government saying who is or is not in the military. Having the government say who is or is not a “minister of the gospel” is a little disturbing. but of course, they also have to decide what is or is not a church or an Indian tribe for that matter.

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It’s Not Just Us Taxapyers That’s Confused

It’s Not Just Us Taxapyers That’s Confused

Suppose, though, that you invest in a partnership and that that partnership invests in some other partnership. What happens is that the partnership you invest in jumps through hoops and then you jump through hoops. The ruling above is reminding agents that the basis hoop and the “at-risk” hoop even though they look a lot alike are not exactly the same. Only individuals and closely held corporations need to be at-risk.

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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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