ILLMAS Posted December 10, 2014 Report Share Posted December 10, 2014 http://www.aicpa.org/publications/taxadviser/2014/may/pages/clinic-story-01.aspx 1 Quote Link to comment Share on other sites More sharing options...
DANRVAN Posted December 16, 2014 Report Share Posted December 16, 2014 The Brown ruling is an good case study of the "placed in service" requirement. Colorfully written, Judge Holmes opens with a quote from Hemmingway. As the drama unfolds, Brown's team of five lawyers is shot down as the IRS lawyers cite case after case in the commissioner's favor. One case in particular that would have seemed to be in Browns favor involved a sail boat waiting for sails that was ruled as placed in service. Ultimately, it is Brown's own testimony that flies back in his face. The Judge notes that this was not Brown's first encounter with the IRS. Notice 2002-59, 2002-2 C.B. 481, was issued to disallow a split dollar life insurance arrangement he helped concoct. That was brought to the IRS attention by an article in the New York Times. Quote Link to comment Share on other sites More sharing options...
Lion EA Posted December 16, 2014 Report Share Posted December 16, 2014 Ah, the rich wanting to get richer! Pigs get fed, and hogs get slaughtered. Quote Link to comment Share on other sites More sharing options...
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