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Most Recent Posts

Expenses Paid with a Forgiven PPP Loan are Deductible, IRS is Wrong

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.

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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a lonely voice out there crying that rather than fooling with the effective date, 461(l) should have been retroactively repealed as it is poor tax policy and unfair.

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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

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IRS Moves To Virtual Settlement Meetings

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.

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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.

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Who Gets The Million Plus Stimulus Checks?

One of Terry’s fascinating theories is that President Trump turns down his salary so that he can continue to be treated as being a real estate professional. Terry also thinks that the President’s switch to Florida residence (which I predicted-not bragging, just saying) was motivated by the state income tax headaches that 461(l) has indirectly created for people with enterprises of his complexity.

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Deep Pockets Need To Return Paycheck Protection Money

There has been an uproar about some of the companies that have taken the money and now we have new guidance from the ever growing FAQ on the Treasury website. In a few years we may be reading a lot about FAQ 31 litigation as not everyone will attend to or be intimidated by the latest guidance. Here is it in full.

“Question: Do businesses owned by large companies with adequate sources of liquidity to support the business’s ongoing operations qualify for a PPP loan?

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