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Most Recent Posts

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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Top Crime Writer Cannot Avoid SE Tax On Book Royalties

Top Crime Writer Cannot Avoid SE Tax On Book Royalties

Karin Slaughter is a very successful writer of crime thrillers. Between her Grant County series and Will Trent series and some stand alone works she has twenty one novels, starting with Blindsighted in 2001.  According to her website people have bought over 35 million copies of her books which have been published in 120 countries.

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Kent Hovind’s Me Too Moment

Kent Hovind’s Me Too Moment

When it comes to real estate California is different from Alabama.  Cindi was going to buy multiple properties to replace the income from the California property.  She already had $700 per month and needed another $1,300 per month.  Why not put an additional $133,000 into the ministry in exchange for an annuity of $1,300 per month?

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A Look At The Opinion On Releasing Trump Tax Returns

A Look At The Opinion On Releasing Trump Tax Returns

I really hope that they don’t decide to make a substantial batch of complete Trump returns public.  Based on what I think I know about the way the Trump Organization is structured – hundreds of disregarded entities – the returns likely run into thousands of pages.  I would then have to choose between going through them or feeling bad about myself. 

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When A Relative’s Wages Become Ineligible For The ERC

When A Relative’s Wages Become Ineligible For The ERC

It may be simple to understand who is a relative of a greater-than-50% owner, but it is often complex to determine who are greater-than-50% owners themselves. Advisers should gather information on all related entities and related individuals to make a full analysis of ownership attribution. Ultimately, a relative of any owner can be at risk ERC wage disqualification.

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