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

Most Recent Posts

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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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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