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Most Recent Posts

When Owner Wages Become Ineligible For The ERC

When Owner Wages Become Ineligible For The ERC

Family attribution of ownership produces unfavorable results by generally disqualifying more wages for the purposes of the ERC. Advisers and taxpayers should take a close look at these rules before claiming the recently expanded benefits of ERC.

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CPAs Should Steer Clear Of Syndicated Conservation Easements

CPAs Should Steer Clear Of Syndicated Conservation Easements

There are twelve investment vehicles mentioned in the indictment.  They have names like Inland Capital Investment Fund 2014, Coastal Property Holdings and Eastern Sierra Holdings 2018.  Easements on 8,236 acres yielded charitable contributions of $956 million.  That works out to $116,076 per acre. Assuming a 37% rate the tax subsidy for the easements would be just shy of 43,000 per acre if the deductions held up.

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Kent Hovind Half Billion Dollar Lawsuit Dies With A Whimper

Kent Hovind Half Billion Dollar Lawsuit Dies With A Whimper

Paul Hansen’s theory that he based the case on is that the jurisdiction of the federal government  is extremely narrow. As far as I can tell the idea is that since the Constitution gives the federal government exclusive jurisdiction over what would become the  District of Columbia and land where there are forts, magazines, arsenals, dockyards and other needful buildings, it has no jurisdiction anywhere else except by contract

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Todays Dollars 2021

This table gives you a today's dollar multiplier rounded to the nearest dollar from the Inflation calculator You will note that the year range varies significantly as...

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Low Income Housing Tax Credit Enriching Private Interests At Expense Of Common Good

The trend of limited partner investors attempting to thwart the ability of nonprofit general partners from exercising their statutorily defined rights of first refusal in low-income housing tax credit (LIHTC) deals is extremely troubling. Such efforts are regularly contrary to law yet costly for nonprofits to litigate, frustrate congressional intent, violate long-held norms and expectations in the industry, and threaten to jeopardize the ongoing affordability of our already scarce federally-assisted housing stock. Nevertheless, investors see an opportunity for windfall profits and are pouncing

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Monetized Installment Sale – IRS Finally Says It Does Not Work

Monetized Installment Sale – IRS Finally Says It Does Not Work

The IRS is aware of this transaction and does not believe it provides the tax benefits being sought.  The cited advice permits monetization of an installment note received in a sale of farm property, which are exempted from the pledge rules generally requiring gain recognition upon monetization on an installment obligation.

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The Dubious Anonymity Of Virtual Currency Transactions

The Dubious Anonymity Of Virtual Currency Transactions

So if you are looking to hide your financial misdeeds, you should be doing it yourself rather than using exchanges.  With Bitcoin, still by far the most popular virtual currency by market capitalization, although not transaction volume, you have to deal with the reality that every transaction ever is preserved in the blockchain and available for anybody to look at.

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Michael Jackson’s Estate Mostly Prevails In Valuation Fight With IRS

Michael Jackson’s Estate Mostly Prevails In Valuation Fight With IRS

Round numbers going into trial the disputed assets were valued at $5 million by the Estate and $482 million by the IRS.  Judge Holmes at $111 million leaned toward the Estate, but it was not a real blowout.  The top estate tax rate in 2009 was 45% so the final check the Estate writes will probably still be, as we say, a number.  The notice of deficiency that prompted the petition that got the litigation rolling had much more dramatic adjustments.  They totaled over $1.1 billion with image and likeness adjusted upward by $434 million, NHT II by $469 million and NHT III by $58 million.

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Boston Tax Institute

Boston Tax Institute

Covid-19 forced a radical shift in the BTI model.  Lucien Gauthier (Lu) has moved to Zoom and he is not moving back.  He was concerned that the interaction with students, many of whom are practitioners with many years of experience would be lost, but it has worked out.

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