Most Recent Posts

IRS Victory In Easement Case Prompts An Offer To Not Be Refused
The decision that I think likely triggered this notice, which I suspect was prepared some time before, was Plateau Holdings LLC (TC Memo 2020-93). As with many of the decisions Judge Lauber approved of the IRS disallowing on a technical error involving the terms of the easement. But in order to assess the penalty valuation has to be considered and that gets to the heart of the matter.

Why Stimulus For The Dead Might Not Have Been So Bad
Overall I think the IRS did a pretty good job particularly given that they went into this “war” with Vietnam War era software as you can see in this article by Tom Temin in Federal News Network earlier this year. Not to mention a huge headcount reduction in the aftermath of the interminable “scandal”.
GAO seems to be concerned about them chasing the erroneous stimulus payments, but given that many of them went to widows and orphans, I think that should be a low priority.
Bottom line is that when Congress wanted money shoveled out quickly IRS thought fast and made mistakes which in retrospect was absolutely the right thing to do.

IRS May Issue Millions Of Notices With Dates Wrong
I think the dumpster fires to get rid of the misdated notices will not be nearly as bad as those created by mailing them.

New August 31 Deadline To Return Required Minimum Distributions
There is not necessarily a right answer, but you want to consider what would be a tax rate that would cause you to want to liberate money from your IRA. This is not a computation you can do by just looking at the rate table. Reilly’s Sixth Law of Tax Planning – Don’t Do The Math In Your Head. The income tax is full of all sorts of thresholds and phaseouts that might affect your decision.

Round Up Of My Student Loan Coverage
I started covering student loans as part of my Occupy Wall Street coverage in 2011. The coverage was from a big picture policy viewpoint. I have now taken up a different approach. I am going to study student loans from my viewpoint as a tax planner. Frankly, I agree that the system is kind of screwed up, but so is the tax system, which accounts for Reilly’s First Law of Tax Planning – It is what it is. Deal with it.

Student Loan Income-Driven Payments- Tax On Forgiveness Should Not Stop You
But the other thing you should do with a problem like that is plan for it, because, under Section 108, debt discharge income is only taxable to the extent that it makes you solvent. So Taylor will only be taxed on $105,344 if Taylor has assets, reachable by creditors, that much or more.

Paul Hansen Provides Legal Theory Behind Kent Hovind’s Half-Billion Dollar Lawsuit
Originally published on Forbes.com. Kent Hovind’s half -billion dollar lawsuit against the federal government and others has him back preaching, if not practicing the...

Kent Hovind’s Half-Billion Dollar Lawsuit – Legal Analysis
What is extraordinary to me is not so much the confidence that they have that they are right. It is the seeming total assurance that they will prevail. Kent explains the “verified complaint” argument with one of his sports analogies. Under Paul John Hansen Law there must be a “verified complaint” in order for a grand jury to consider an indictment.
They have asked the clerk of the court for a copy of the verified complaint. There is not one. So under Hansen law that means that even though federal prosecutors hit a home run with Kent’s 2006 conviction, long sentence and property forfeiture which was upheld on appeal, it was all for naught, because they failed to touch first base as they rounded it.

Who Is IRS Aiming At In Recent Partnership Notice?
The information you have is not the information you want. The information you want is not the information you need. The information you need is not the information you can obtain. The information you can obtain costs more than you want to pay

Paycheck Protection, Churches And The Constitution – It’s Complicated
There are cases where I assume the professors would agree that churches may receive public services. I suspect that they do not object when local police or fire departments respond to problems at church buildings. By the same token, one could envision public policies so targeted at religious institutions that no plausible First Amendment justification can be proferred for them. There would, for example, be no tenable constitutional defense if Congress adopted a program exclusively subsidizing clerical salaries.