Most Recent Posts
PPP IRS And Tax Deductions – Is Resistance Futile?
Originally published on Forbes.com. A Treasury news release makes it clear that the IRS is holding firm to its negative view on deducting expenses paid by forgivable...
IRS Threatens 75% Fraud Penalty For Investors In Syndicated Conservation Easements
The answer is the same for both types of partnerships. The fraud penalty is determined at the partnership level. In order to assert the fraud penalty the IRS must prove “by clear and convincing evidence, the elements of the fraud penalty based on the partnership-level conduct and intent of the manager(s) of the partnership”. What the investor partnersh though is really not relevant.
Ms. Black makes it clear that there is nothing different about SCEs in this regard compared to other partnerships.
Coca-Cola And Amazon In Tax Court – Where Are The Intangibles?
Why are the supply points, engaged as they are in routine contract manufacturing, the most profitable food and beverage companies in the world? And why does their profitability dwarf that of TCCC, which owns the intangibles upon which the Company’s profitability depends?
A Syndicated Conservation Easement Deal With Substance
Originally published on Forbes.com Judge Robert Goeke of the United States Tax Court approved a $17.5 million 2012 charitable deduction disallowance in the case of...
Ryan LLC – Tax Consulting Firm That Let Go Of CPA Brand
There were many gimmicks that were supposed to lead CPAs to the promised land of free money. There was “efficient auditing”.Figure out how little work you could do and still issue an opinion. Financial services. Get the money manager to cut you twenty-five of the hundred or two hundred basis points they charged. India – that vast pool of brilliantly educated incredibly hardworking people willing to work for a pittance. I know. I have a bad attitude
One concept that seemed to have some merit to it was “value billing”. Just marking up an hourly rate can only get you so far. There was a group that included engineers that would go in and look at a clients operation; They would determine that just about everything that they did was research and development qualifying for the credit. The group charged based on tax savings rather than hours worked.
A significant amout of Ryan LLC’s work appears to be billed on that sort of basis. Brint Ryan took it a step further and designed a work environment that paid people based on value rather than how many hours they logged at the office.
Is A Major IRS Crackdown On Partnerships Looming?
Jerry Curnutt has been a voice crying out in the wilderness since 2000 when he retired from IRS as a GS 14. He believes that there are vast amounts of unrecognized partnership gain getting by the IRS. Partnerships with large negative capital just wink out from the IRS Business Master File. If you think like an accountant, you expect there to be a final return where everything goes to zero, which arguably would require gain recognition
Senate Investigation Of Easement Syndications Worth Celebrating
This investigation involved reviewing hundreds of additional emails, which generally repeated the subjects discussed above. The transaction promoters were selling tax deductions, and their taxpayer-investors were buying them. The investigation did not uncover a single email from a single promoter, responding either voluntarily or to a subpoena, that reflects a taxpayer’s primary interest being the development of land, and this investigation did not uncover a single email that a reflected a taxpayer’s primary interest being the conservation of land.
Education Of A Tax Court Judge
Cadet Lauber’s status as a “rich kid” would not have meant all that much inside the school. Everybody was wearing the same uniform. And not even seniors were driving cars to school. Students could distinguish themselves academically, athletically, with military zeal or in a variety of activities or as authority scorning malcontents.
Asked about the effect of the military aspect of the school he mentioned the strict discipline. But when probed on that he spoke of the Prefect of Discipline, a Jesuit priest. The reign of terror that passed for discipline was actually Jesuit enforced. JROTC just gave it a bit of a military favor with “jug”- Jesuit high school detention – being supervised by cadet officers and NCOs with some marching and standing at attention and hall monitors being designated MPs.
Tax Court Will Go Dark For December
I actually kind of like the notion of a month of silence from the Tax Court. My original blogging strategy was to read as much current original source material as I could and write about the things that I find interesting. The Tax Court was by far my best source.
Over the years though rather than having my posts be essentially reactions to opinions, I have done more digging. Also I have found that there are ongoing story arcs that demand attention. Kent Hovind alone could keep me going if I had more patience with Youtube. Bottom line is that I have fallen woefully behind in reading current cases and the December hiatus will give me a chance to catch up.
But what will happen to Lew Taishoff? Mr. Taishoff blogs the Tax Court with fierce intensity. He posts on decisions before the ink is dry on them or maybe we should say while the electrons are still excited. And he even goes through the Tax Court orders. Well he has made it through government shutdowns and other dry spells. So I suppose that he will make it through this drought.
Trump Seven Springs Easement Deduction May Be Reasonable
The Seven Springs easement is real and it is on a property that he owned a long time. The New York AG probably is politically motivated in pursuing this. The Post has done some really good work here and they weren’t afraid to report a competing narrative, so they deserve a lot of credit. Other than that. Not much to see here, folks.