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

Most Recent Posts

Former IRS Investigator Joe Banister Loses Appeal Of Aiding And Abetting Penalties

Former IRS Investigator Joe Banister Loses Appeal Of Aiding And Abetting Penalties

Back in 2003, the IRS Office of Professional Responsibility revoked Banister’s right to represent clients before the IRS.  He had that right as a CPA. A follow on to the OPR ruling would be revocation of his CPA license, but that is neither here nor there.  The revocation was appealed to the Ninth Circuit where it was sustained.  Among the things involved in the revocation was his raising the 861 argument.  He should have known better so he can no longer represent taxpayers.  Since the issue of him making a bad argument has been litigated once with respect to the revocation, he does not get to fight it again with respect to the penalty.  That was the District Court ruling.

read more
Tax Court IRS And Secret Law

Tax Court IRS And Secret Law

The Tax Court is letting us down when it comes to electronic transparency. Public documents, such as briefs and petitions, that are readily available from other federal courts are effectively inaccessible to those of us who don’t live or work in the nation’s capital. And maybe the IRS and even some law firms like it that way.  Rather than write about this abstractly, I would like to show it to you as we go along. I’m going to use a decision I recently blogged about –  an important hobby loss case (Section 183).

read more
Donald Trump Floridian

Donald Trump Floridian

 
One of the problems with the New York to Florida switch is that being a New Yorker is a very distinctive identity – Floridian not so much.  And Trump for all his many faults in my mind is a  consummate New Yorker.  He can register to vote in Florida, file a Florida domicile declaration and apply for a homestead exemption on the family residence portion of Mar-a-Lago.  Those are the basics, but what else can he do?

He can read A Land Remembered or at least talk about what a great book it is, even if he never reads it.  He can have one of his minions read it for him.  Beyond that, he can start using his twitter account to signal his change in loyalties. 

read more

Flow-Through Relief – Senate Version Of Tax Bill Is Much Better For The Little People

One of the themes of the various Republican campaigns was about how awful it was to have a 70,000-page tax code.  Never mind that that was inflated by a factor of more than ten.  Making the Code shorter was a priority.  It is true that the bill might make returns easier for most of the little people because a lot fewer people will itemize.  The taxation of business income is, however, much more complex under either version.  And with the Senate leaving the AMT in effect, I think we will see the page count increase significantly.

read more
Stunning Tax Court Victory Against IRS In Horse Case

Stunning Tax Court Victory Against IRS In Horse Case

Earlier this month I had the pleasure of meeting Mr. Taishoff.  I spent the day in Manhattan and managed to arrange a lunch with him at a little French place where I had Le Burger.  I managed to grab the check and Mr. Taishoff nodded approvingly as I wrote his name on the back of the credit card receipt before starting the long walk to the statue of George M. Cohan who did not have to concern himself with such things.

read more

Citigroup Ready For Sharp Earnings Hit If Tax Cuts And Jobs Bill Passes

So Citigroup is ready, but it is not clear that anybody else is.  If President Trump does get a bill to sign with the big corporate rate cut and the deemed repatriation, analysts in the future will have to put an asterisk next to 2017 earnings when they are looking at trends.  It will be interesting to see how shocked everybody is when the earnings reports come in.

I expected that the tax cut would have a favorable impact on Apple’s earnings to the tune of over nine billion dollars, but I was only thinking about its deferred tax liability.  Apple has $232 billion in untaxed foreign earnings and will get hit with some percentage of that from the deemed repatriation, if the bill passes.  Why did I look at Apple?  Well its ticker AAPL is first in the alphabet.  I will leave it to my readers to work their way through the rest of the S&P.

read more