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Most Recent Posts

S Corp To Partnership Conversion Under Build Back Better

S Corp To Partnership Conversion Under Build Back Better

If you and your sibling start a business with capital contributions, run it without debt, and don’t have other owners coming and going, there is a good chance that your individual returns will work out roughly the same whether the partnership or the S corporation form is used.  That is until one of you wants to be redeemed or, you know, dies while the other continues on.

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Time To Change Your Estate Plan – Again

Time To Change Your Estate Plan – Again

I sometimes think that the estate and gift tax system is actually a white collar jobs program for college graduates not quite smart enough to become physicians or engineers.  It redistributes wealth from the upper class to the upper middle class.  Too bad this is going to ruin the holidays for them.

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Trying To Get IRS To Shut Up About Conservation Easement Litigation

Trying To Get IRS To Shut Up About Conservation Easement Litigation

For purposes of section 6103 of the Code, a disclosure that does not name Mr. Clark still identifies him if it contains information that, combined with other information available at the time of the disclosure or that becomes available subsequently, permits persons generally knowledgeable with the relevant transactions and industry to identify Mr. Clark.

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IRS Hangs Tough On Conservation Easements

IRS Hangs Tough On Conservation Easements

What would be really equitable would be for the IRS to allow donors and land trusts to retroactively fix documents that fail the requirement.  The abusive syndicated conservations easements deserve to be crushed, but it should not be at the expense of legitimate deals.

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Did IRS Robots Cause The Tax Court Petition Flood?

Did IRS Robots Cause The Tax Court Petition Flood?

The part of the problem that is most apparent to me is the IRS computers continue to issue CP series notices and more when the answer to their issues is somewhere in the great warehouse of unopened mail. Documentation. Amended returns. And on and on.

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Tax Court Swamped By Flood Of Petitions

Tax Court Swamped By Flood Of Petitions

If you are currently being audited and the agent wants you to extend the statute of limitations, consider telling them to pound sand (in a nice way) and be prepared to file a Tax Court petition in the event they forge ahead with a notice of deficiency.

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Michael Jackson Case Could Support Income Tax Savings

Michael Jackson Case Could Support Income Tax Savings

And this is where the opportunity for shenanigans might arise.  If the heirs donate the image and likeness to an appropriate charity which will commit to making sure it is not sullied, they might be able to find an appraiser who will be able to construct a narrative that yields significant value.  Since the plan will never be executed you can’t say that it would not work.

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