Mary Ann Evans 360x1000
George F Wil...360x1000
1trap
2gucci
399
storyparadox3
Adam Gopnik 360x1000
1confidencegames
2transadentilist
Stormy Daniels 360x1000
8albion'
Margaret Fuller4 360x1000
Spottswood William Robinson 360x1000
Maurice B Foley 360x1000
AlexRosenberg
Tad Friend 360x1000
Lafayette and Jefferson 360x1000
Learned Hand 360x1000
199
lifeinmiddlemarch1
1lauber
Maria Popova 360x1000
4albion
Margaret Fuller 360x1000
4confidencegames
1theleasofus
1defense
Margaret Fuller5 360x1000
Betty Friedan 360x1000
1falsewitness
13albion
2albion
9albion
7albion
5confidencegames
LillianFaderman
Thomas Piketty1 360x1000
Margaret Fuller1 360x1000
Anthony McCann2 360x1000
6confidencegames
Thomas Piketty3 360x1000
2confidencegames
2lookingforthegoodwar
Ruth Bader Ginsburg 360x1000
1gucci
Gilgamesh 360x1000
299
2theleastofus
James Gould Cozzens 360x1000
1lafayette
George M Cohan and Lerarned Hand 360x1000
1madoff
6albion
Mark V Holmes 360x1000
3albion
Margaret Fuller2 360x1000
lifeinmiddlemarch2
Susie King Taylor2 360x1000
11632
3confidencegames
Brendan Beehan 360x1000
3theleastofus
Margaret Fuller3 360x1000
Thomas Piketty2 360x1000
1jesusandjohnwayne
11albion
2lafayette
Office of Chief Counsel 360x1000
Susie King Taylor 360x1000
5albion
1paradide
10abion
2trap
Margaret Fuller 2 360x1000
2defense
499
Storyparadox1
1albion
1lookingforthegoodwar
14albion
2falsewitness
storyparadox2
1transcendentalist
3paradise
2paradise
Anthony McCann1 360x1000
Samuel Johnson 360x1000
Edmund Burke 360x1000
2jesusandjohnwayne
3defense
1empireofpain
7confidencegames
Richard Posner 360x1000
12albion

Most Recent Posts

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.

read more
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.

read more
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.

read more
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.

read more
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?

read more