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

Most Recent Posts

TIGTA Documents The Wreck Of Tax Compliance

TIGTA Documents The Wreck Of Tax Compliance

A possibly apocryphal tale I heard from an IRS criminal investigator was about an old timer who was criticized for not keeping up his firearms proficiency.  His answer was that he had put away a lot more guys with his pencil.  The technology is different, but what will convince people to be compliant is a lot more actual action dosing out painful but moderate consequences, not the occasional dramatic arrests that attract media attention.

Regardless of all that, pay your taxes. It is the right thing to do.

read more

Historian Argues Ronald Reagan’s 1981 Tax Cut Led To Trumpism

Hopelessness is a mighty political force and therefore it should not be so surprising that after the failed promises and benign neglect of three Republican and two Democratic administrations spanning a third of a century, the have-nots came to believe that only a strongman will change the course of the ship of state. The uneducated, those who experienced the alienation of downward social and economic mobility, or the disappointment of wage stagnation for a generation while others were living the lifestyle of the rich and famous, those who were clobbered subsequently by the tsunami of hyperglobalization, and those who were evicted from their homes while the Lords of Finance were being pampered, were ripe to revolt and turn against the establishment elites. Trump was able to harvest the anger of those who reached for the American Dream and found a nightmare instead.

read more

EcoVest Wraps The Green Flag Around Tax Shelter

The fellow who explained to me how you might hit the high multiple home run explained to me that as you go from an original owner to an investor to a developer to a developer/builder, they each expect to experience a lift.  The discounted cash flow analysis has all the lift going to the early player and the subsequent hypothetical developer and developer-builder working for a predictable return while shouldering the downside risk.  Of course, since they are imaginary they don’t complain.

read more

Opportunity Zones – Look Great For Everybody Except Investors

Because of the way it is likely to connect to financial statement issues, the tax work on OZ funds probably is pretty much a lock for CPAs.  EAs and unenrolled preparers probably don’t have much opportunity except insofar as their clients invest in OZ funds or own property in OZs.

If you are early in your career, what is the percentage in becoming your firm’s OZ expert?  It could turn out to be a dead end, but there is always the example of Mike Novogradac who took out a flyer on the historic credit and LIHTC and now runs a top fifty firm with his name on the door.

read more
On The Basis Of Sex – About That Pentagon Computer

On The Basis Of Sex – About That Pentagon Computer

At any rate, when it comes to primary evidence I have James Bozarth who is portrayed as having come up with the idea, who indicates he never heard anything about it.  And I have added to that.  Richard Stone is listed as one of the attorneys on the brief going up to the Supreme Court.  He wrote to me:

Sorry to disappoint, but a draft of the cert petition came to me in a neat package from the Tax Division. My job was to recommend to The S.G. Whether or not to file and to rewrite the draft. I would not have been involved in the gathering of information and have no recollection of the computer use.

That does not nail it, but I think that if Appendix E had represented a technological watershed like the breaking of Enigma, there would have been some scuttlebutt about it.

read more
Sometimes You Crack The Code And Sometimes The Code Cracks You

Sometimes You Crack The Code And Sometimes The Code Cracks You

The conspiracy that Mr. Hendrickson alleges is mind-boggling and slightly bizarre.  The income tax is very narrow, but key elements of the executive and judicial branches pretend otherwise.  The IRS knows that it is hoodwinking most people so it will give the money back to just about everybody that asks for it.  It’s kind of like the technology charge that my managing partner had us implement for a while.

The explanation that I think is more probable, that Mr. Hendrickson thinks is preposterous, is that underfunding, aging technology and declining headcount have crippled the IRS enforcement capacity and that there is a lot that will get by that should not get by.

What you might want to consider is when it is that poor enforcement makes it so that the income tax is, in effect if not principle, voluntary.

read more
Low 1040 Refunds Threaten Household Finances

Low 1040 Refunds Threaten Household Finances

I don’t know whether the stories I read about people not being able to come up with four hundred bucks for an emergency are a sign of the times or a pretty universal condition.  Think about Dr. Lydgate in Middlemarch or the father in Mill On The Floss .  (If you have not read those works by George Eliot, finish this post and start on them.  They are free on Kindle).  If you are counting on your tax refund for solvency and your income is not on the abject poverty side, take a close look at your spending.  It is really boring old fart advice, but sitting here in an RV in Florida at 67, I can tell you it works.

read more
Tax Story Generates Excitement Because Of Minor Nick Saban Connection

Tax Story Generates Excitement Because Of Minor Nick Saban Connection

As it happens I know somebody who is currently attending the University of Alabama.  I reached out to him to find out why a Tax Court decision that marginally affected Saban would seem like a story to the sports press.  He wrote me:

In Tuscaloosa, sororities will sometimes paint signs on their window proclaiming that Nick Saban, a 5’6″ 67 year old man, is the sexiest person alive. For reference, I’ve never seen any player treated the same.

So I guess it is not surprising that a Tax Court decision that marginally involves him can generate interest.

read more
Notice 2019-07 250 Hour Requirement – What It Means And How To Meet It

Notice 2019-07 250 Hour Requirement – What It Means And How To Meet It

Regardless, I would recommend that it is worth going to the trouble of complying.  There are different approaches to representing taxpayers at audits.  One guy I know goes with a hostile combative style.  Some attorneys will adopt a litigation posture, forgetting that it is the client that has the burden proof.

My approach is that I am working with my fellow accountant who just happens to have a government job to arrive at the correct answer.  Of course, I know that the correct answer is “no change”. My brother or sister accountant, verging on becoming my new BFF,  just needs a little help to see that.  Lavishing attention on something that is easy to get right helps in the process.  That’s my theory anyway and, knock on wood, I’ve done pretty well over the years.

So ask your vendors for hours (not including drive time) and ask your real estate management company if they will provide you with a “Notice 2019-07 Compliance Report”.  It’s going to be a thing. I’m sure of it.

read more
Here Is The First Post On A 2019 Tax Court Decision

Here Is The First Post On A 2019 Tax Court Decision

The name of the petitioner is, of course, public record and you can easily find it, but it is one of those cases where I figure the taxpayer does not need me to help him be more famous so I will call him Joe.  The case is pretty much a mess and I would normally skip it, but I figure my readers must also be suffering from Tax Court Withdrawal Syndrome.

read more