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

This was originally published on PAOO on 6/8/10.

Private Letter Ruling 201016097

There is a bit that Steve Martin does where he tells you how to make a million dollars and pay no income tax. It’s a very simple plan. First you make one million dollars. Then you pay no income tax. He then addresses the possibility that the IRS might contact you. Simple. You just say “I forgot”.

Any time I see something of such elegant simplicity I want there to be something to it. Some kernel of truth hidden in the nonsense. When it came to Steve Martin’s routine, though, I despaired Until now.

Private Letter Ruling 201016097 was not directed to Steve Martin. The ruling is directed to a taxpayer who is 82 and according to Wikipedia, Steve was born in 1945. Nonetheless it finally vindicates him as a tax advisor. The taxpayer withdrew all the money from a Roth IRA and failed to put it into a rollover Roth within 60 days. The head note to the ruling indicated that the failure was “due to her mental health conditions which affected her ability to handle her financial affairs”. (That “her” is another clue that it wasn’t Steve Martin, himself, applying for the ruling). More on the gender issue follows.

I thought we might be heading to a punch line involving you have to be crazy to blow a roll over deadline, but I was delighted on deeper reading to find an illustration of the Steve Martin Rule (We need to specify Steve to avoid confusion with Martin Ice Cream, a key decision on personal good will). As we read about Taxpayer A moving funds from IRA Account X to non IRA account Y at financial institution M. We find “Taxpayer A represents that he suffers from a condition which impairs his memory.” There it is. “I forgot.” Whether the memory issues having anything to do with the gender transformation between the head note and the third paragraph is a question left unanswered.

Taxpayer A was granted relief. He or she may have forgotten about the whole thing by now, but the rest of us can remember the next time we are in a jam to say “I forgot.”

Oh by the way :

Any tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein