The Never-Ending Battle
In every era and area of law you find a never-ending battle between two groups of legal thinkers: formalists and functionalists. Each is connected to long-standing and honorable traditions in Anglo-American jurisprudence. The formalists tend toward the law side of those traditions the search for order and certainty and the functionalists tend toward the equity [...]
The Section 734(b) Basis Adjustment Needs Repair
The partnership tax provisions – Subchapter K of the Internal Revenue Code – work pretty well. And they have a difficult job to do because they must provide a reasonable mechanism for taxing arrangements between parties that can be far from off-the-rack. It should not be difficult to figure out how to tax two individuals [...]
Prying Open The Closet Door: Doma And Tax Treaties
I. INTRODUCTION In the wake of the events surrounding President Bush’s endorsement of a constitutional ban on same-sex marriage,[2] a conservative, “pro-family“ organization[3] wrote the Commissioner of the Internal Revenue Service (IRS) earlier this year to alert him about “a potential fraudulent tax scheme.“[4] The organization was alarmed by “rebellious state and local officials reportedly [...]
The Mysteries of Erroneous Refunds
I love my yearly tax refund. I know I’m not supposed to, but I do. Theorists argue that my refund represents an interest-free loan to the government and I am supposed to resent that for reasons grounded in the obsessive individualism of our culture. But even accepting the argument’s premise, the value to me of [...]
The Tax Lawyer—Robert Wood “IRS Bill Dispute”
The Tax Lawyer—Robert Wood “IRS Bill Dispute” law,lawyer,IRS,Billnews,lbnfinances,rob,wood,financial Author: LBNstudio
Taxnami 2011 – , Credits and Funding of the Healthcare Legislation
Taxnami 2011 – , Credits and Funding of the Healthcare Legislation IRS,2010,2011,2012,2013,2014,healthcare,legislation Author: Berrylawoffices
Voluntary disclosure of offshore accounts
Things are getting ever more uncomfortable for U.S. taxpayers holding undisclosed offshore bank and investment accounts. And in the wake of the very public fight between the Internal Revenue Service and Union Bank of Switzerland (UBS), it is quite possible that one of your clients will reveal to you that he has an offshore account [...]
Taxnami 2011 – How much is grandma going to be taxed?
Taxnami 2011 – How much is grandma going to be taxed? ,estate ,2011,2010,2012,IRS,estate planning Author: Berrylawoffices
Sheldon Hosts Information Session for Small Businesses on New Tax Credits
Sheldon Hosts Information Session for Small Businesses on New Tax Credits Sheldon Whitehouse,Senator Whitehouse,small business,SBA,health care reform,Small Business Jobs Act,Rhode Island,IRS,tax breaks Author: SenatorWhitehouse
Offers in compromise after TIPRA
After the Bankruptcy Abuse Prevention and Consumer Protection Act you thought it couldn’t get any worse for your tax delinquent clients? Wrong again. The latest Congressional gift to the IRS Collection Division is Section 509 of the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA). One must at least give grudging credit to the [...]
C – FEDERAL Income TAX IN US IS ILLEGAL – Ex IRS AGENT INFORMS US ALL – PART 2
C – FEDERAL Income TAX IN US IS ILLEGAL – Ex IRS AGENT INFORMS US ALL – PART 2 FEDERAL,Income,IN,US,IS,ILLEGAL,Ex,IRS,AGENT,INFORMS,ALL Author: youpolitics
Tara revisited – The new “innocent spouse” rules
Scarlett: But Rhett darling, our Separation Agreement requires you to pay any taxes resulting from the IRS audit that was going on during our divorce. Now Revenue Officer Sherman has levied my wages and seized my horse and my last mint julep! Rhett: Frankly, my dear, I don’t give a damn. Sound familiar? Ever represent [...]