Most Recent Posts
Bob Dylan’s Debt To Nashville – It’s About Taxes
Dylan’s reach was really amazing. Sister Kathleen Reilly, who was a year younger than Dylan, told me that when the older nuns at the Pallotine motherhouse in Harriman, NY were upset about various things that were different from the good old days of habit wearing, the younger nuns would break into a chorus of The Times They Are A Changin’.
Vacation Home Conversion, Debt Discharge And Partnership Issues All In One Tax Court Case
When you borrow money secured by property whether the debt is recourse or nonrecourse can have tremendous tax significance. From an economic viewpoint, you want the debt to be nonrecourse. The idea is that if you can’t pay, you hand the bank keys and you are done. Sometimes though you can get that deal with recourse debt. It is called a “short sale”, which has a different meaning in real estate than it does on Wall Street.
Law Professor Argues Opportunity Zone Program Is Harmful
It seems though that the impetus to tinker with the Code to achieve goals other than raising the right amount of revenue with the least collateral damage is irresistible. Tax expenditures have a way of seeming like a free lunch. So when a young billionaire reflects on how to make the world a better place by directing capital to areas that need it, why not add another section to the Internal Revenue Code? If it works society will have gotten quite a bang for his activist bucks.
Kent Hovind’s Hail Mary Pardon Pass
As I write this Kent’s vote fraud video is at 5,500 views. There are a lot of ifs, but if it takes off and gets some love from people actually connected with Trump, who knows? President Trump has been complaining about how mean the IRS has been to him, why not do something for Doctor Hovind?
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