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Most Recent Posts

Billionaire Miami Dolphins Owner Gets Shut Out At Tax Court

Mr. Ross had pledged $4 million (later raised to $5 million) for a University of Michigan athletic center. RERI’s donation of the SMI was done under an agreement that provided that there would be a $1 nominal credit to the pledge, that the University would hold the interest for two years and then sell it crediting Mr. Ross’s pledge with whatever was received for the interest.  The appraised value of the SMI used for charitable donation purposes was $32,935,000.

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Failure To Get Bank Subordination Fatal To Easement Charitable Deduction

Failure To Get Bank Subordination Fatal To Easement Charitable Deduction

The fact is that we all have to live somewhere so housing in and of itself is not counter conservation.  Golf on the other hand is. I can’t think of a hobby that takes up more acreage.  Take up hiking instead.  It has all the health benefits of golf, is a lot cheaper and hiking trails are a lot less disruptive to the environment.  Maybe I’m on a crusade because my covivant and I have become volunteer trail maintainers.  We live next door to a golf course which I walk by almost daily.  It really does not stand up to the trail when it comes to preserving the natural environment.

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Congress To IRS – Hands Off The President’s Favorite Charitable Tax Dodge

A small group of promoters are offering packaged conservation easements.  I have not seen any of their presentations, but someone who has tells me that they are very slick.  They might promise tax deductions as much as 250% or more of the amount invested.  Bradford Updike, an attorney, is the only person I have spoken with who thinks it is possible for these things to be legitimate.  He wrote Conservation Easements: The Federal Tax Rules And Special Considerations Applicable To Syndicated Transactions.

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IRA Withdrawal Penalty A Cost Of Do-It-Yourself Divorce

IRA Withdrawal Penalty A Cost Of Do-It-Yourself Divorce

A couple of months later the court entered a consent decree for the dissolution of the marriage incorporating the agreements that Robin and Terry had made.  Since the IRA account had been cleaned out there was no mention of it.  Robin reported the $17,378 on his return but did not report any “additional tax” on line 58. The custodian of course had ratted him out, by sending 1099 to the IRS with “early distribution, no known exception” indicated.

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Billionaire Bruins Owner Beats IRS On Tax Deductions For Away Game Meals

Billionaire Bruins Owner Beats IRS On Tax Deductions For Away Game Meals

Since the whole away team crew is away from its business home, the IRS does not question that the meals are deductible.  Generally, though, the deduction for meals is limited to 50% (Code Section 274(n)).  There are exceptions.  There were two that the Bruins owners argued they qualified for.  One was that the meals were a “de minimis” fringe benefit and the other was that they were an expense of entertainment sold to customers.  The first excuse turned out to be good enough, so the Tax Court did not discuss the second one.

It might seem odd, but a footnote indicates that the IRS was not proposing an adjustment with respect to meals provided to players and staff in TD Gardens in Boston, but that is the key to the controversy.

In order to qualify as de minimis fringe benefits the meals must be provided in  a non-discriminatory manner.  There did not seem to be any issue about that.  The more challenging requirement is that the meals be provided at a facility owned or leased by the employer located on or near the business premises of the employer.  That’s why there was no question about meals provided for home games

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