3paradise
2falsewitness
storyparadox2
Stormy Daniels 360x1000
2jesusandjohnwayne
Margaret Fuller2 360x1000
13albion
1falsewitness
299
7confidencegames
1jesusandjohnwayne
Learned Hand 360x1000
Margaret Fuller3 360x1000
Spottswood William Robinson 360x1000
James Gould Cozzens 360x1000
AlexRosenberg
Margaret Fuller1 360x1000
Thomas Piketty1 360x1000
10abion
Margaret Fuller 2 360x1000
11632
4confidencegames
7albion
2gucci
Storyparadox1
Richard Posner 360x1000
Margaret Fuller 360x1000
Office of Chief Counsel 360x1000
1lafayette
2trap
Samuel Johnson 360x1000
2paradise
2transadentilist
3albion
Maurice B Foley 360x1000
lifeinmiddlemarch1
1madoff
1lauber
Ruth Bader Ginsburg 360x1000
2albion
4albion
12albion
1trap
Brendan Beehan 360x1000
14albion
2theleastofus
Thomas Piketty2 360x1000
Mary Ann Evans 360x1000
Susie King Taylor2 360x1000
2confidencegames
2defense
499
9albion
8albion'
storyparadox3
Lafayette and Jefferson 360x1000
Maria Popova 360x1000
Mark V Holmes 360x1000
George M Cohan and Lerarned Hand 360x1000
3confidencegames
lifeinmiddlemarch2
George F Wil...360x1000
2lafayette
6confidencegames
399
1confidencegames
11albion
1lookingforthegoodwar
Susie King Taylor 360x1000
Betty Friedan 360x1000
1theleasofus
Tad Friend 360x1000
Thomas Piketty3 360x1000
1transcendentalist
Margaret Fuller5 360x1000
Anthony McCann2 360x1000
Margaret Fuller4 360x1000
1paradide
Gilgamesh 360x1000
Edmund Burke 360x1000
Adam Gopnik 360x1000
Anthony McCann1 360x1000
6albion
1defense
2lookingforthegoodwar
199
5albion
LillianFaderman
1gucci
1albion
1empireofpain
5confidencegames
3defense
3theleastofus

Most Recent Posts

IRS Wins Most Hobby Loss Cases But Don’t Let That Intimidate You

If your client has something that they want to do and can tell you with a straight face that they are trying to make money at it, you should counsel them to take the losses, but only if they are willing to act in a businesslike manner. Separate accounts. Strong substantiation. But most importantly at least once a year talk to your client about why there were losses and what they are going to do differently in the future in order to change things. Document those discussions.

It does not matter that profitability is improbable, it just has to be sincerely pursued.

read more
Tax Planning For The High Salary Pauper

Tax Planning For The High Salary Pauper

Back in days of very high marginal rates – 70% federal – people who made their money by working got a break. Their was a maximum tax on income from, you know, working. And there were shelters. Many were sketchy and abusive and could get you in trouble, but some like low-income housing were blessed. You could defer your income and when the deferral turned around it was taxed at capital gains rates.

Now it seems that there are breaks for everybody, except the high salaried. Of course, if you are prudent with a very high salary you will accumulate net worth and ultimately be able to do some fancy stuff, if you are so inclined.

read more
Major Crackdown On Conservation Easements Or IRS Bluff?

Major Crackdown On Conservation Easements Or IRS Bluff?

Conservation easement charitable deductions are a relatively benign tax expenditure. The idea is that somebody who owns property with a highest and best use different from its current use should be able to give up the right to develop in the interest of conservation and receive a charitable deduction (Note I am simplifying here).

When you give something to charity your deduction is generally the fair market value of what you gave. The best way to arrive at fair market value is through comparable sales. But people don’t buy and sell conservation easements very much, if at all.

So you value the easement by figuring out the value of the property without the easement and subtract the value of the property with the easement. It is the before value that is a problem, because we have to think about what you might do with the property.

read more

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.

read more

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.

read more