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Tax Court Rules International Waters Not Foreign Country But Misses That Mariners Are Not Marines
The Court is not aware of a valuation issue between the parties. Petitioner had employed his preparer for 20 years and relied upon his expertise to report that petitioner’s income was exempt under section 911(a). The preparer was informed about petitioner’s residence and the facts surrounding his income earned during international voyages on cargo ships. The reporting position had been approved for earlier years, and it was reasonable for petitioners to rely on the preparer under these circumstances. Accordingly, we hold that petitioners are not liable for accuracy-related penalties with respect to any underpayments that may result from our holding on the section 911(a) issue.
The Epilogue Class (1971) Gathers- 1970 – The Xavier Class Lamented By Antonin Scalia – Part VII
My account of Xavier High School's last years as a "thoroughly military academy" to quote one of Xavier's most famous if not most beloved sons - Antonin Scalia Class of...
High Flying Insurance Agent Could Not Stop IRS Jeopardy With Let’s Make A Deal
When Mr. Brown’s representative had a telephone conference with the IRS settlement officer it was indicated that the only “distrainable asset” was $5 million of equity in the residence. The plan to pay the IRS off in installments would be based on Mr. Brown obtaining financing in order to buy a pool of insurance policies that would produce a flow of income. He promised further details which came in the form of a 300 page document.
Kent Hovind And Attacks On Eric Hovind – Method In The Madness?
Kent Hovind gets the ball rolling for his new bigger better Dinosaur Adventure Land in Lenox Alabama. Attacks on Eric Hovind continue. When Kent talks about his dispute...
$16 Million Golf Course Conservation Deduction Disallowed On Fine Points
One of the requirements of a deductible easement donation is that it be in perpetuity. An implication of that is that the easement has to be superior to any mortgages. So you have to get the entities holding mortgages to subordinate. Hillcrest did subordinate, but the subordination was not filed until several months after the easement deed. Taxpayers argued that there was an oral agreement in place to get the subordination, but that did not cut it. So no deduction
Expatriate Lawsuit Featuring Rand Paul Shot Down
James Bopp, Jr., the lead lawyer for the Plaintiffs and General Counsel for Republicans Over-seas, states the following: “The Court refused to permit us to amend the complaint to fix the Court’s alleged problems it found originally in our complaint and then dismissed our case. The Court’s theory is that it is the fault of the banks for refusing to do business with American citizens, not the fault of FATCA which causes the banks to do it. This is like blaming the bank cashier for robbing the bank when the robber puts a gun to her head and she gives him the bank’s cash. That cannot be correct.”
Kent Hovind May Be Calling Off The Hounds
It looks like Kent Hovind may be regretting just a bit the fury that he unleashed by going public with his dispute with his son Eric over control of ministry assets....
Claiming A Conservation Easement Deduction? Use A Tax Attorney
One of the requirements to make a conservation easement deductible is that the conservation purpose be “protected in perpetuity”. That is a really long time. And there is recognition that maybe things will change and that in the future people will think that it would be better if we just paved everything. So there is a kind of out. If due to unexpected changes the conservation purpose can no longer be fulfilled then there can be a clause that says that the donee organization gets a cut of the proceeds.
AMT Credit Carryover Dies With The Taxpayer
The other practical observation from a planning viewpoint is to note many valuable tax attributes even for example basis in excess of value will die with the taxpayer. There may be planning opportunities that present themselves. Consider a taxpayer with large charitable carryovers or net operating losses and substantial IRA assets. It might be worth ending the income deferral while there are attributes to shelter it rather than leaving behind an income tax liability.
Bill Sardi Thinks Eric Hovind Should Be Polishing His Resume
I heard from Bill Sardi who has some thoughts on the current conflict in the Hovind family that has spilled into the public sphere. Kent mentioned Bill around the 7:00...