Taxation & Estate Planning

TaxProf Blog Crosses 10 Million Visitor Mark

Posted on June 04, 2010

WSJ: IRS Seeks to Treat Nursing Home Entrance Fees as Taxable Pre-Paid Rent, Not Tax-Free Interest-Free Loans

Posted on June 04, 2010
Wall Street Journal, Retirement-Community Operator Battles IRS Over Entrance Fees, by John R. Emshwiller: Classic Residence by Hyatt, a group of businesses that run upscale retirement communities, is battling the IRS over allegations it underpaid its taxes by more than $107 million, in a dispute over the tax treatment of...

IRS Is Big Winner in Shift of Phillies-Jays Series from Toronto to Philadelphia

Posted on June 04, 2010
Major League Baseball's decision to move the June 25-27 Blue Jays-Phillies series from Toronto to Philadelphia to avoid the G-20 summit being held in Toronto will cost Phillies ace Roy Halladay, who picthed for the Blue Jays for 12 seasons, $75,000 in additional federal income tax...

Rahm Emanuel Pays Delinquent Property Tax After Being Questioned by Media

Posted on June 04, 2010
From WBBM Newsradio 780: White House Chief of Staff Rahm Emanuel was three months behind on his property tax payments until Newsradio 780 brought it to his attention. Rahm Emanuel and his wife accumulated a $445.56 penalty for the payment delay on their four-bedroom Ravenswood home...

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Tax Court Petition in Nursing Home Entrance Fee Case

Posted on June 04, 2010
Following up on this morning's post, IRS Seeks to Treat Nursing Home Entrance Fees as Taxable Pre-Paid Rent, Not Tax-Free Interest-Free Loans: the Tax Court case is CC-Development Group, Inc. v. Commissioner, No. 7383-10. The Notice of Deficiency asserts $107...

7th Circuit Judge Relocates Chambers to Indiana-Bloomington

Posted on June 04, 2010
From yesterday's Indiana-Bloomington press release: The Honorable David F. Hamilton, judge of the United States Court of Appeals for the Seventh Circuit, today announced plans to relocate his chambers to the Indiana University Maurer School of Law in Bloomington...

Powell: A Quick Guide to the Generation-Skipping Transfer Tax

Posted on June 04, 2010
Mark E. Powell (Chapman) has posted The Generation-Skipping Transfer Tax: A Quick Guide on SSRN. Here is the abstract: Sooner or later, every estate planner comes face-to-face with the generation-skipping transfer tax. Many practitioners do not feel up to the challenge because this particular tax as a reputation as being...

Hillary?s Revealing Tax Gaffe

Posted on June 03, 2010
Following up on Tuesday's post, Top 5% (>$212k/year) Earn 30% of Income, Pay 40% of All Taxes; Hillary Clinton Says That's Not Enough -- Urges Global Push for Tax Increases: Reuters, Hillary?s Revealing Tax Gaffe, by James Pethokoukis: Democrats believe America?s wealthy still aren?t paying their fair share...

Call for Business Tax Papers: Conglomerate Junior Scholars Workshop

Posted on June 03, 2010
The 2010 Conglomerate Junior Scholars Workshop has issued a Call for Papers: If you are finishing up a scholarly article this summer on a topic that may be interesting to Conglomerate?s readers ? such as corporate law, securities, contracts, business tax, finance, antitrust or law and economics ? we would...

2d Cir.: Capital Contribution Does Not Increase Shareholder's Basis in Loan to S Corp

Posted on June 03, 2010
The Second Circuit yesterday affirmed a Tax Court ruling (131 T.C. 262 (2008))that capital contributions made to two S corporations in which the taxpayers owned stock could not be treated as ?tax-exempt income? to the corporations for the purpose of increasing their basis in loans they made to the corporations...

10th Annual Oregon Tax Institute

Posted on June 03, 2010
The two-day Tenth Annual Oregon Tax Institute kicks off today in Portland. Tax Profs with speaking roles include: Martin J. McMahon, Jr. (Florida), Current Developments in Federal Income Taxation Scott A. Schumacher (University of Washington), Current Ethical Issues in Tax Practice

Will Washington Bail Out the Mainstream Media With an iPad Tax?

Posted on June 03, 2010
Reuters, Will Washington Bail Out the MSM With an iPad Tax?, by James Pethokoukis: This is actually quite astonishing. A ?staff discussion draft? from the Federal Trade Commission recommends ways the government can save journalism. First, it lists a number of ways Washington can subsidize the media (to the tune...

NY Times: Several States Delay Tax Refunds

Posted on June 03, 2010
New York Times, Half a Dozen States Delay Tax Refunds: Hawaii Iowa New York North Carolina Rhode Island

TIGTA Submits Semiannual Report to Congress

Posted on June 03, 2010
The Treasury Inspector General for Tax Administration today submitted its Semiannual Report to Congress: It is my pleasure to submit this Semiannual Report to Congress that highlights the many accomplishments of the Treasury Inspector General for Tax Administration (TIGTA) over the past six months...

IRS Names Charlotte Crane 2010-11 Professor-in-Residence

Posted on June 03, 2010
IRS Chief Counsel William J. WIlkins has named Charlotte Crane (Northwestern) as the 2010-2011 Professor in Residence: The IRS Professor in Residence reports directly to the Chief Counsel and provides advice and assistance on a variety of legal issues within the scope of his or her expertise...

D.C. Ballpark Tax Funds City's Operating Budget

Posted on June 02, 2010
Washington Examiner, Ballpark Tax May be Here to Stay: A citywide business tax the D.C. Council passed to help to help pay for the $611 million Washington Nationals ballpark has become such a cash cow that the city is now using it to help close its nine-figure budget gap...

ABA Tax Section Hosts Webcast Today on Current Developments in Circular 230

Posted on June 02, 2010
The ABA Tax Section offers a teleconference and webcast today on Hot Topics and Current Developments in Circular 230 from 1:30 - 3:00 p.m. EST: The Office of Professional Responsibility (?OPR?) has been expanded recently in light of the Service?s interest in upgrading the quality of tax practice and as...

Woman Sues Google for Bad Directions

Posted on June 02, 2010
Associated Press L.A. Times New York Daily News PC World Time (Hat Tip: Jim Maule.)

Let the Good Times Roll!

Posted on June 02, 2010
New York Times, Happiness May Come With Age, Study Says: It is inevitable. The muscles weaken. Hearing and vision fade. We get wrinkled and stooped. We can?t run, or even walk, as fast as we used to. We have aches and pains in parts of our bodies we never even...

Call for Tax Papers: Houston Business and Tax Journal

Posted on June 02, 2010
The Houston Business & Tax Law Journal has issued a call for tax papers: The Houston Business and Tax Law Journal welcomes your submission on any subject relating to the treatment of social entitlements in the tax system. Our goal is to have a thought provoking symposium that addresses the...

Morse: Revisiting Global Formulary Apportionment

Posted on June 02, 2010
Susan C. Morse (Santa Clara; moving to UC-Hastings) has posted Revisiting Global Formulary Apportionment, 30 Va. Tax Rev. ___ (2010), on SSRN. Here is the abstract: This Article examines global destination sales-based formulary apportionment (?DSFA?)...

Harvey Joins Villanova Grad Tax Faculty as Distinguished Professor of Practice

Posted on June 02, 2010
J. Richard (Dick) Harvey will be joining the full-time faculty of Villanova Law's Graduate Tax Program as a Distinguished Professor of Practice. From the Villanova press release: Professor Harvey is currently the Senior Advisor to IRS Commissioner Doug Shulman and is responsible for providing him guidance on matters of policy...

IRS: California Registered Domestic Partners Can Split Income and Tax Withholding 50/50 Without Adverse Gift Tax Consequences

Posted on June 02, 2010
The IRS on May 28 issued three important rulings dealing with tax issues faced by same-sex couples who are registered domestic partners under California law. Priv. Ltr. Rul. 201021048 (May 5, 2010): Taxpayer must report on his individual federal income tax return one-half of the combined income that Taxpayer and...

Subscribing to TaxProf Blog

Posted on June 01, 2010
We offer two ways for you to have TaxProf Blog content automatically delivered to your computer, cell phone, or mobile device, as explained in the left column of the blog under the banner, "Subscribe to TaxProf Blog Via RSS Feed or Email": RSS Feeds: You can subscribe to one of...

Columbia Journal of Tax Law Publishes Second Issue

Posted on June 01, 2010
The Columbia Journal of Tax Law has published its second issue (Vol. 1, No. 2): David M. Hasen (Penn State, moving to Santa Clara), Legal Transitions and the Problem of Reliance, 1 Colum. J. Tax L. 120 (2010): "This Article analyzes the literature on legal transitions...

Clark: Ruminations on the Government's Position in Textron

Posted on June 01, 2010
Kenneth B. Clark (Fenwick & West, San Francisco) has published Ruminations on the Government's Position in Textron, 127 Tax Notes 1017 (June 1, 2010): The Textron decision may become even more important in light of the IRS?s decision to require disclosure of information relating to tax reserves...

Tax Amnesties, Justice Perceptions, and Filing Behavior

Posted on June 01, 2010
Silvia Rechberger, Martina Hartner, Erich Kirchler & Franziska Katharina Hämmerle (all of University of Vienna, Department of Psychology) have published Tax Amnesties, Justice Perceptions, and Filing Behavior: A Simulation Study, 32 Law & Pol'y 214 (2010)...

TaxProf Blog Holiday Weekend Roundup

Posted on June 01, 2010
Saturday: Today's Law, Society, and Taxation Panels Schnider: Are ISOs Dead Because of the AMT? The Promise and Dilemma of Conservation Easements Conservation Easements in Private Practice Sunday: Top 5 Tax Paper Downloads Bartlett: A Pox on Tax Expenditures Today's Law, Society, and Taxation Panel Framing the FairTax Monday: Memorial...

Tax Extenders Bill Includes Small Business Tax Increase

Posted on June 01, 2010
Joe Kristan was the first to flag a particularly odious aspect of H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010 currently making its way through Congress: small businesses would be hit with a 2.9% medicare tax increase which would not apply to larger competitors: Joe Kristan,...

Top 5% (>$212k/year) Earn 30% of Income, Pay 40% of All Taxes; Hillary Clinton Says That's Not Enough -- Urges Global Push for Tax Increases

Posted on June 01, 2010
Tax Policy Blog, Rich Pay 40% of Nation's Tax Burden, Hillary Clinton Says Its Not Enough, by Scott A. Hodge: Ben Smith at Politico has posted a video of Hillary Clinton stating that she does not think America's rich are paying their fair share of taxes...

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