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Most Recent Posts

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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All That Glitters is Not Taxed.  Or is It ?

All That Glitters is Not Taxed. Or is It ?

Where do virtual world transaction take place? – Yuan, a free lance professional WOW player in China raids several tough dungeons and earns 10,000,000 gold. He sells it to a wholesaler for $10,000 who will sell small lots of 500 gold to recreational players in every state in the United States for them to buy better armor or epic mounts within the game. Where did this happen? Can the US tax Yuan? Can Massachusetts tax the wholesaler who is located in Texas? Can Illinois, where the server is located, tax everybody?

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