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

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