Most Recent Posts
Ben Sheffler Reflects On His Time With Interlock Media Covering Kent Hovind Trial
I recently posted a piece that is somewhat of a critical of a short documentary by Interlock Media called Dr. Dino: Creationism, Conspiracy, Conceit - The Politics of...
Kent Hovind, Interlock Media And The Allure Of Conspiracy
Just as Watergate has its Woodward and Bernstein and the Boston Archdiocese abuse scandal had the Globe Spotlight team the 2015 trial of Kent Hovind had a team of...
IRS Chief Counsel Denies Basis Mitigation From Estate Tax Increase
In order for the mitigation provisions to apply, the first requirement is that there be a determination, as defined by IRC section 1313(a). The decision of the Tax Court in the estate tax (Form 706) case is what the estate is relying on as the determination. While this may appear to meet the definition of section 1313(a)(1), it is our position that it does not.
Because the value of the asset was determined through settlement negotiations that did not result in agreement on the merits, but instead resulted in a general agreement on the appropriateness of settlement in order to resolve the case, the mitigation provisions do not apply and the refund claim should be denied as untimely.
Wrong Attachment Kills Tax Court Jurisdiction
In order to determine whether Mr. Frausto maintains the capacity to represent the corporation under Rule 60(c), we must first apply the proper State law. The record, however, does not show in which State, if any, the corporation was organized. In fact, Mr. Frausto chose not to attend the hearing where he could have provided the relevant information. Thus, in the absence of any evidence to support our jurisdiction over the corporation, we hold that Mr. Frausto does not have the capacity under Rule 60(c) to litigate in this Court on behalf of the corporation.
Airplane Tax Deductions Do Not Fly For Urologist
There was an attempt to compare Dr. Steinberger’s situation to that of Peter Morton, co-founder of Hard Rock Cafe, who was allowed to treat his jet owning S corporation as part of a unified business. I covered the Court of Claims decision on that shortly before moving over to forbes.com. The Court’s response to the comparison must have stung a little seeming to imply that Dr. Steinberger was just not as cool as Peter Morton.
Sons Of Xavier Keep Dancing – An Interlude In My Account Of The Decline Of The Regiment
I left off this account of the decline of the military at Xavier High School in the Fall of 1968, as we started our Junior Year. Those of us who got good grades and...
Kermit Washington Indictment And The Allure Of Zero Overhead Charity
Taking Mr. Washington as at face value, he was moved to be very hands on his charitable activities. When he raised money he wanted it to go directly to the people in need and he emphasized this in his appeals. A fund -raising email that is quoted in the indictment stated: “there is no and I mean no administration cost at all”.
What Mr. Washington stands accused of in the indictment are things like diverting fees that he was entitled to PCA and then PCA funds to personal use. Then there is that software license ebay thing. And there is backdating of minutes. The really oddest thing is aggravated identity theft for listing Teresa Gipson as the Secretary of Project Contact on the Annual Report, without, you know, telling her about it. And then there were the 990s. Don’t get me started.
Some sound administration including if the dollars warranted it reviewed and audited financial statements would have helped Mr. Washington avoid the temptation to fall into these foolish moves. And they are foolish. Regardless of Kermit Washington’s guilt or innocence on the indictment, he will not go down in history as an accomplished fraudster.
When Penalties Are Punitive They Are Not Tax Deductible
BI is a US corporation with a foreign subsidiary that is treated as a disregarded entity (DE). DE’s executives and employees falsified books and records to cover up things of value given to government officials. There were not adequate internal accounting and financial controls to detect and prevent corruption-related violations under the Foreign Corrupt Practices Act. There are about two paragraphs worth of details redacted. I’m sure they would make this post much more entertaining.
BI entered into a consent decree with the SEC to pay a disgorgement of profits from its FCPA violations. Part of the deal was that they could not consent to the penalty while denying the allegations. Then there was an agreement by DE with DOJ consenting to the filing of a Criminal Information and the paying of a monetary penalty for which no tax deduction could be taken. The fine on DE that was paid by BI caused a dollar for dollar reduction in the disgorgement penalty on BI.
Third Circuit Rules Grocery Store Chain Can Deduct Perks Sooner Rather Than Later
By disallowing deductions claimed on the basis of established recurring expenses, the Tax Court effectively obliterated the distinction between two accounting methods expressly authorized by the Tax Code.The extent to which cash and accrual methods of accounting sometimes yield different deductions is a byproduct of the Tax Code’s design. So long as a taxpayer consistently adheres to one accounting method, the Code is agnostic as to the benefit or hardship wrought by his selection
Daniel Berrigan And Those In The Silent Generation That Did Not Shut Up
Just over a week ago, I found myself watching a live stream of the funeral mass of Father Daniel Berrigan. My reaction was probably a little different from most. I...