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Most Recent Posts

President Trump Now A Florida Man

President Trump, if challenged by New York, will have to establish that he has abandoned his New York domicile and established a new domicile in Florida. This will be challenging given that he is actually living in Washington DC. (DC is clearly not his domicile though, because he has to move out of his residence in either January 2021 or January 2025).

The other problem I see is that it is hard to establish that you have become a Floridian because it is not quite the distinctive identity that being a New Yorker is. And domicile does turn on irrational factors. That was the basis of the advice that I gave back in 2017, which still stands.

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Ed And Elaine “Show Me The Law” Brown May Be Released Soon

According to the Bureau of Prison Inmate Locator, Edward Brown, age 77, has a release date of 7/26/2045 and Elaine Brown, age 78, has a release date of 11/8/2042. Clearly, the sentences that they received in 2009 were virtually life sentences. They had been prosecuted as the result of a months long armed stand off at their home in New Hampshire. They had been resisting surrendering to serve a 2007 sentence related to tax resistance activities.

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AI Coming For Tax Planners – The Horror

The product looks like it could be very useful for someone doing litigation or audit representation on the issues that it covers. In the type of large local/regional CPA practice I grew up in, I think that it might not get enough use to justify spending not just the money on the product but also the time you would need to spend to get really comfortable with it. If I had a niche practice focused on an issue that is covered, I think I would run right out and buy it.

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Auditing The IRS: What Is Coming In 2020

Auditing The IRS: What Is Coming In 2020

Determine whether the IRS has implemented policies, procedures, and practices to ensure that compensation is considered in examinations of closely held S Corporations and their shareholders.

TIGTA 2020 Audit Plan

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Beto O’Rourke, IRS And The Constitution

Beto O’Rourke, IRS And The Constitution

States tend to have the Attorney General’s office regulate not-for-profits not their revenue departments. For some reason at the federal level it falls to the IRS, which is actually a bad choice particularly in its current beleaguered states, but politicians and activists of all sorts are quick to call the IRS to step in to effectively shut down groups by revoking their exemptions for matters that have nothing to do with taxation.

It’s silly. As we saw with the interminable scandal, the IRS is terrible at it and it detracts from its very important core function of collecting revenue.

It’s also bipartisan. Ben Carson reflexively called for the revocation of the exemption of an Islamic group that was critical when he was running for the Republican nomination in 2015.

Just stop it. Have the IRS bring in the money. That’s a big enough job for them.

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Grassley To IRS On NRA – Fight Crime Someplace Else

As a raw junior accountant doing line-ups (Copying the account number and names on thirteen column worksheets and preparing depreciation and prepaid insurance schedules to make life easier “in the field”), I would observe a lofty senior packing his audit bag.

If Herb was nearby, the routine was always the same. “Where are you going?” Herb would ask. The senior would respond with a client name. Herb would invariably say “Bring back a check”.

And if the IRS is going to help with the deficit that is what the Commissioner should be thinking when he sends out his dwindling supply of auditors. Will they be bringing back a check? (Technically they bring back assessments and it is the collection people who bring back the checks, but that is neither here nor there.)

Investigating the NRA will not bring in any revenue to speak of, so leave it to the FBI or whoever should be looking into the matter.

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GAO Reports On Charity Tax Abuse

If the IRS only has enough staff to do a hundred audits of abusive transactions involving tax-exempts, it’s hard to see how better analysis will help all that much.

“As we discussed earlier in this report, IRS’s Research, Analysis and Statistics office also has developed the capability to analyze narrative information, which it has tested on the Form 8886. However, this analytical tool is not being used operationally to review the Form 8886 or any other disclosure report. Our analysis shows that the tool has the potential to help IRS better search disclosure reports for additional information about transactions that could help IRS identify potentially abusive schemes involving tax-exempt entities.”

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Expats Need Expert Tax Advice

Expats Need Expert Tax Advice

Given their jobs as intelligence analysts Elena and Federick are probably smarter than most CPAs and EAs, myself certainly included. Nonetheless, hiring someone with some specialized tax knowledge would have been money well spent. The Tax Court sustained deficiencies of nearly $90k and penalties close to $40k. And those are from the years 2004-2006, meaning the interest will be, as we say, “a number

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Partnership Tax Returns – Why Do We Even Bother?

Partnership Tax Returns – Why Do We Even Bother?

Sorting out the types of discrepancies that TIGTA is highlighting requires people. And the IRS has fewer and fewer people every year. According to the IRS data book, the head count in 1999 was 98,730. In 2018, it was 73,519. Now if you believe as some do, that “taxation is theft”, that is 73,519 too many, but those of us who believe that taxation is the price we pay for civilization, it is crazy to keep gutting enforcement.

Gutting tax enforcement, however, is perfectly consistent with the libertarian drive to starve the beast outlined in Christopher Leonard’s – Kochland: The Secret History of Koch Industries and Corporate Power in America, which is a really good read by the way.

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