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Most Recent Posts

Tax Court Judge Considers Passing On Deductions Unbusinesslike

Tax Court Judge Considers Passing On Deductions Unbusinesslike

And it was quite a yacht.  The Triumphant Lady was purchased in 2001 for $4,950,000.  In 2006 a refit was started which ended up costing $10,839,000 by the time it was finished in 2009.  The Lady had a full-time crew under the command of Captain Bryan Pridgeon.  It was used personally by the Steiners until 2009.

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Warren’s 7% Solution: Privatization Of Corporate Tax Measurement

There is a very interesting proposal kind of buried in the Real Corporate Profits Tax.  The notion is that at least with respect to RCPT, the definition of income would be significantly insulated from the political process. I did not see anything in the Warren material that indicated that it is FASB that should determine the measure of taxable income, but that is the effect.

I actually think that a case might be made for a system that worked like that.  It could shrink the Internal Revenue Code substantially.  It would preclude using the Tax Code as an instrument of social policy, which I think many of us think would be a good thing.

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Cautionary Tax Tale For Consultants With Long Term Gigs

It does make me reflect on how he might have done better.  Overall, I think he should have boosted the substance of his overall business.  In principle, it should not matter, but I suspect he would have done better as an S corporation.  Saving some money on the SE tax, might have offset any additional cost.  The 1120S would have been small potatoes and his individual return would have been more mundane.

Filing three Schedule Cs was probably a bad idea, as I noted.  And he should have made a stronger case that his home near Atlanta was actually the hub of his business.  Since his agreement with AFR was terminable on short notice, it is hard to see what purpose it served him, but it might have been meant to address concerns about him being treated as an employee.

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National Accounting Firm Launches Cannabis Practice

He also indicated that there is a bit of a feel of the dot.com boom about the excitement that is being generated.  The difference he sees is that the companies have real products and revenue models.  I remember that before they called it the dot.com boom, it was called the New Economy, where things like profits and cash flow no longer mattered.  Apparently, that is not what is going on in the cannabis boom.  Just watch out that they don’t start growing tulips.

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Selling Your Business – Watch Out For Effect On 199A Pass-Through Deduction

The provision of the Tax Cuts and Jobs Act that right now is giving the most stress to tax preparers is probably Section 199A also known as the pass-through deduction. Sitting in an RV in a state park in Georgia, I once again am grateful that I retired from doing compliance work.  Not having any current returns to crank out gives me time to think about the effect that 199A might have on deal structuring.

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Grassley Wyden Take On Sketchy Conservation Tax Shelters

Grassley Wyden Take On Sketchy Conservation Tax Shelters

The highest and best use is going to be something hypothetical.  This is where things can get out of hand. The development to bring the property to its highest and best use is not something that actually has to be executed. So there can be a tendency to think big and assume away minor obstacles like zoning.  There was one case where the proposed development didn’t even fit on the parcel.  I mean – So what?  It’s not like you were going to actually build it.

On top of the valuation issue, there are times when the donee organizations are a little sketchy and won’t really be able to enforce the easements.  And sometimes the conservation or public benefit of the easement is altogether dubious.  Sometimes easements are given on properties that are already so restricted that there is no real value to them.  I compare those to me renouncing my superpowers.

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Hobby Loss Claim Goes Down In Flames

The captain’s initial plan was to sell rides on the plane. (The Firefly had a crew of two, so I guess the passenger would get the navigator/weapons officer spot)   Of course, that required making the 60% restored Firefly 100% flyable.  That took eight years and 45,000 man-hours.  Some of the tsoris involved is outlined in this story by John Sotham in Air&Space.

When the plane was ready for its intended use, basis had grown to $1.6 million which translated into annual depreciation deductions over $80,000.  It turned out that taking up passengers who could fantasize about dropping bombs on the Tirpitz or Japanese submarines was not feasible.  So Captain Eddie took to the air shows, where the plane did quite well, but to live in fame did not bring in enough revenue to cover expenses.  Losses mounted up.

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