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

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