Most Recent Posts
Syndicated Conservation Easements- An Industry Based On Nonsense
Conservation-easement cases might have been more reasonably resolved case-by-case in contests of valuation. The syndicated conservation-easement deals with wildly inflated deductions on land bought at much lower prices would seem perfectly fine fodder for feeding into a valuation grinder. Valuation law is reasonably well known, and valuation cases are exceptionally capable of settlement.
Paycheck Protection Certification – No Harm No Foul
Basically nobody who had an actual business and did not blatantly lie on the application will have cause to regret having chased PPP money. Given the speed which the program was thrown together and the vagueness of the certification, this is clearly the right answer.
If there was an attempt to penalize companies because they were being piggy in applying, litigation would have dragged on for years. I might have found it entertaining, but no good would have come of it.
Trump Abandons Dock Dispute But State Income Tax Exposure Remains
But the matters uncovered in the dock dispute, raise a big red flag on the effectiveness of President Trump’s switch. There was a contract uncovered that indicated that he could not use Mar-a-Lago as a residence-that he could not stay there more than three non-consecutive seven day periods just like any other member of the club.
And that brings us to the question of domicile. It is possible that more than one state can tax you as a resident based on how much time you spend there and some other factors (It’s called the New York rule), but you will almost inevitably be taxed as a resident in your state of domicile even in years when you spend no time at all there.
Could Donald Trump’s Dock Battle With Mar-A-Lago Neighbors Cost Him Millions In New York Taxes?
Why the concern about states taxing capital gains? Other than the general Republican belief that tax cuts are a kind of universal solution to every problem. Is the President thinking about making his severance with New York complete by selling his iconic properties and resenting the whopping tax bill on the gains regardless of his domicile status?
Paycheck Protection Deductions: If No Help From Congress Should You Help Yourself?
I’m going to stick my neck out and predict that quite a few taxpayers will take the deduction, many of whom will be blissfully unaware of the notice. If the IRS decides to pay attention to the matter, somebody will litigate it and I really think it could go either way.
Expenses Paid with a Forgiven PPP Loan are Deductible, IRS is Wrong
No court has ever ruled, nor would it ever rule, that cancellation of debt that is claimed to be non-taxable pursuant to existing exclusions, whether that be due to insolvency or bankruptcy under Section 108 or pursuant to Section 1106 of the CARES Act, somehow requires a taxpayer to amend prior-year returns to remove deductions attributable to the non-taxable cancellation of debt.
A Defense Of The Break Republicans Snuck Into The CARES Act
The coverage on this move, which apparently was a fast one in that the voting came before the scoring, has been negative. There is a lonely voice out there crying that rather than fooling with the effective date, 461(l) should have been retroactively repealed as it is poor tax policy and unfair.
Judge Urges Prison Furlough For Author Of “Biggest Tax Fraud Ever”
With many well-heeled felons like Zukerman able to afford the costs of getting a motion for early release before a court, one hopes that the BOP takes a proactive approach with other inmates who do not have the same resources. While the pandemic should not necessarily amount to a get out of jail card for all felons, it should not amount to a pass for only those who can pay for their freedom
IRS Moves To Virtual Settlement Meetings
A lot of people represent themselves in Tax Court. That it is why you don’t need to watch situation comedies or reality TV if you read Tax Court decisions like I do. Some of them, particularly lawyers and engineers, represent themselves because they are so smart. That often does not end well. Others do so because they can’t afford representation or the stakes are too low to make it worthwhile.
IRS Rains On The Paycheck Protection Parade
PPP can still be a really good deal and I think it would be worth testing the IRS on this. I am close to certain that more than a few taxpayers will take the deduction anyway and the matter will end up in the courts unless Congress quickly clarifies this one way or the other.