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While Eli and the gang ready themselves for Sunday’s game, team ownership is preparing to fight it out in court over a $1,500,000 property tax bill East Rutherford says the team owes.

At the root of the issue is whether the team’s new training facility — which was built with private funds as part of the construction of Met Life Stadium — should enjoy the same tax-exempt status as the old state-owned Giants Stadium.

The team argues that the current training facility is grandfathered under the previous, tax-exempt arrangement:

“The new stadium replaced the old stadium. The Giants had a practice facility here and offices here. Now they have a practice facility and offices. Nothing has changed.”

From the county’s perspective, however, the Giants gave up the right to its property tax exemption when it borrowed $650,000 of private money to construct its current facility. As Mayor James Cassella put it,  “It’s an office building…Why should someone who owns an office building, built by a private company, not pay taxes?”

Of course, if the Giants have too much pride to lay down on Sunday, they could also try and cover their tax bill by laying $150 bucks at 10,000 to 1 that they’ll win by more than 29 but less then 33 points. It could happen, right?  Right????

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Managing the tax law is no different than installing hardwood, baking a casserole[i], or concocting an email that bilks the unwary by posing as the deposed prince of Nigeria: the devil is in the details. 

Take, for example, the case of Francis[ii] and Maureen Foster.[iii] A well-intentioned couple, they believed they had met the statutory requirements of a straight-forward tax provision, but by mishandling some subtle non-tax housekeeping, they cost themselves $8,000.  

In February 2006, the Foster’s put their home of 30 years on the market, though the property didn’t sell until June of 2007. During the 16 months between the initial listing and the subsequent sale, the Foster’s made several damaging administrative missteps:

  • They moved in with Mrs.. Foster’s parents, but failed to pay rent or any portion of the utilities.    
  • Mrs. Foster renewed her driver’s license at the old address, rather than at her parent’s address.
  • They used the old address on their 2005 tax return.  
  • During 2006 and 2007, the Fosters continued to visit the old home, where they maintained all utilities services, requently stayed overnight, and received mail.
  • On a 2007 rental application, the Foster’s again listed the address of the old home as their primary residence.

In July 2009, the Foster’s purchased a new home and claimed the $8,000 first-time homebuyer’s credit on their tax return. The IRS disallowed the credit in full, arguing that the Foster’s failed to qualify as first-time homebuyers.

The Service based its position on  I.R.C. § 36(c)(1), which defines a “first-time homebuyer” as any individual having no present ownership interest in a principal residence for three years prior to the date of purchase of a principal residence. The IRS argued that since the Foster’s hadn’t sold their previous primary residence until June 2007, a date only 2 years prior to the purchase of the new home, they failed to qualify for the credit.

The Fosters, to the contrary, argued that the ceased using the old home as a principal residence in February 2006 when they listed it for sale, and thus qualified for the credit as three years had passed prior to their purchase of the new home.

The Tax Court sided with the IRS, citing the damaging facts and circumstances bulleted above as evidence that the Foster’s continued to use their old home as their primary residence even after they moved out and until it was sold in 2007.

The takeaway lesson, quite obviously, is that paying attention to detail could have preserved the credit for the Fosters. Had they taken the steps necessary to distance themselves from their old home — by paying rent to Mrs. Foster’s parents, switching the address used for their licenses, tax returns, mail service, and rental applications to their temporary home and by cutting off any non-essential utilities and ceasing visitation at their old home  –  the Foster’s would likely be $8,000 wealthier today.


[i] Or so I’m told.

[ii] Note, the court did not indicate whether Francis Foster preferred to be called “Psycho.”

[iii] Foster v. Commissioner, 138 T.C. 4 (1.30.12)

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On Wednesday, we posted a quick tutorial on how to determine the deductible amount of mortgage interest when total mortgage debt exceeds the statutory limits. While we briefly mentioned that any interest in excess of the allowable amount was subject to the interest tracing rules, we failed to expand further on this concept.

Lucky for us, on Thursday the Tax Court explained the interest tracing principles beautifully, providing a ready-made supplement to our previous post.[i] 

Robert Brooks (Brooks) worked for Dain Rauscher (Dain) as a stock broker. As part of his compensation, Dain lent him more than $500,000, which Brooks promised to repay, including accrued interest. Dain, however, promised to forgive the loan, including the accrued interest, if Brooks remained a Dain employee.[ii]

In 2003 Dain forgave the entire loan and included $650,342 ($506,300 in principal and $144,042 of accrued interest) on Brooks’ 2003 Form W-2. Brooks recognized the income on his 2003 tax return, but upon a subsequent IRS audit, he changed his position and argued that the accrued interest of $144,042 should not have been included in income.

The basis for Brooks’ argument lay in I.R.C. § 108(e)(2). In general, I.R.C. § 61 requires all cancellation of indebtedness (COD)income — including cancellation of any accrued but unpaid interest — to be included in income of the debtor. An exception to this general rule is found in I.R.C. § 108(e)(2), however, which provides that a debtor will not realize COD income to the extent payment of the liability would’ve given rise to a deduction.

Thus, the determination of whether Brooks could exclude the forgiven interest depends entirely on whether it would have been deductible on Brooks 2003 tax return had he actually paid it: if it would have been, Brooks could exclude the income; if it would not have been deductible, then the forgiven interest must be included in Brooks’ taxable income.

To determine the deductibility of the interest, the interest tracing rules must be applied. These rules generally allocate interest expense based on the use of the debt proceeds. Stated in another manner, Brooks was required to prove what the money borrowed from Dain was used for; if it was used in a trade or business, to generate investment income, or for the production of income under I.R.C. § 212; the underlying interest would be deductible as business interest, investment interest, or I.R.C. § 212 interest, respectively. To the contrary,if the proceeds were used for personal purposes, any interest would be non-deductible personal interest.[iii]

Brooks argued that the loan proceeds were used to purchase shares of stock, and thus the underlying interest should be deductible as investment interest. The Tax Court disagreed, for two reasons:

1. Brooks did not provide adequate support for how the borrowed funds were used. The only proof he provided was to point to the long list of stock transactions he attached to his 2003 return, which the court held was not sufficient to “trace” the use of the funds.[iv]

2. Even if the use of the funds could be traced to the purchase of stock, the interest would be investment interest, which is subject to limitation. Investment interest is only deductible to the extent a taxpayer has “net investment income,” defined as investment income less related expenses. Because Brooks had no net investment income in 2003, no investment interest would have been deductible by Brooks even if paid in 2003. Since payment of the interest would not have given rise to a deduction, I.R.C. § 108(e)(2) would not apply, and Brooks would be required to include the forgiven interest in income.


[i] Brooks v. Commissioner, T.C. Memo 2012-25.

[ii] The real issue here, as recognized by the Tax Court, was whether the loan should have been treated as compensation to income to Brooks when it was made in 1998. Since neither parties argued that the loan proceeds were compensation in 1998, the Tax Court “looked the other way” on the matter.

[iii] I.R.C. § 163(h)(1).

[iv] Brooks should have presented bank account statements and brokerage account records to show the flow of funds from Dain to Brooks to the purchase of stock.

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Here at Double Taxation, we tend to highlight the lighter side of the Tax Court, with topics ranging from the application of the hobby loss rules to drag racing to trophy wife-related theft losses to charitable contributions for crazy cat ladies.

But tax trials are serious business; and if you’d like to stay out of the court room, it’s helpful to know the most frequently litigated issues.  To that end, the IRS Taxpayer Advocate’s annual report has you covered:

Most Frequently Litigated Tax Issues: June 1, 2010 – May 31, 2011
1. Summons Enforcement 132
2. Trade or Business Expenses 107
3. Collection Due Process 89
4. Failure to File and Estimated Tax Penalties 74
5. Gross income 62
6. Accuracy Related Penalties 55
7. Civil Actions to Enforce Federal Tax Liens or to Subject Property to Payment of Tax 48
8. Joint and Several Liability 44
9. Frivolous Issues Penalty 44
10. Charitable Deductions 27
1,045. Medical Expense Deductions for Visits to Prostitutes 1

So how does one leverage that information to increase their chances of a Tax Court victory? Dean Zerbe over at Forbes offers some advice:

Trade or business expenses.  For individuals the problem continues to be having good books and records to support the deduction of expenses – especially for travel and entertainment expenses.  

A number of cases in this area also get into the question of whether the taxpayer is deducting expenses (and claiming losses) for a legitimate “for profit” activity.  As a general rule, I’ve found the IRS takes a dim view of businesses that involve animals – horse training, cat raising, etc.  If you aren’t making a profit in your animal business, be ready for an IRS letter, particularly if you are claiming a loss from the activity and deducting as a business expense your subscription to “Cat Fancy” or “Horse and Hound” magazines, as well as the cost of kitty litter, oats, etc.  Don’t be surprised if the IRS deems your animal fancy a hobby.

Gross income – What counts as income.  Damage awards top the list here.  While payments due to physical injury or sickness are not subject to tax, other damage payments are (ex. payments for emotional distress).  The effort to avoid this issue should start by having a tax attorney involved with the final settlement agreement.  Always a big help if you ensure that a settlement makes clear what the payments are for.

Charitable Deductions.  This is a new one for the list of litigated issues.   Congress and the IRS have cracked hard on taxpayers taking an expansive view of the value of certain charitable deductions. If you think your Yugo that goes only in reverse is worth 20k as an antique – think again.  Good valuation is the key to success – and keeping your feet on the ground in what you claim especially in areas such as conservation easements.

Zerbe saves his best advice for last; recommending how to make nice with the IRS before things ever escalate to the point of litigation:

Of course the best way to win in court is never to end up there in the first place.  So if you’re audited, first, when the IRS is knocking on your door – this is not the time to be a spendthrift – get your tax professional involved early in the process as positioning is everything.  Second, listen closely and understand fully the IRS’ concerns. Third, provide the IRS documentation and legal support justifying your positions and addressing the IRS issues.  Fourth, exercise your rights for review at IRS appeals and mediation. Finally, I am a big believer that you need to be on offense when dealing with an IRS audit. 

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In a move made popular by so many retirees tired of the rat race, Rutgers University football coach Greg Schiano is fleeing the Garden State for the palm trees and sandy beaches of Florida. Schiano is not heading south to live out his days playing shuffleboard and poaching the early-bird specials, however. To the contrary, he just accepted a 5-year contract to coach the NFL’s Tampa Bay Buccaneers.

Schiano leaves New Jersey as the State’s highest paid public employee, with an annual salary approaching $2,400,000. Now, Schiano’s salary with the Bucs is yet to be disclosed, but even if it doesn’t represent a raise from his annual Rutgers wage, Schiano stands to put an additional $175,000 a year in his pocket each year. How can I know this?

Tax rates, of course.

Schiano is leaving New Jersey, a state with a top personal tax rate of 8.97%, for Florida, which has no personal income tax. So assuming Schiano was raking in a total of $3,000,000 per year at Rutgers[i] and continues to do so as coach of Tampa Bay, by shifting his domicile to Florida, he stands to save $173,307 per year in state income tax.[ii]

Clearly, the Buccaneers have some attractive assets — most notably, a young, highly regarded QB Josh Freeman, a talented defensive line rotation and a dynamic wide-out Mike Williams —  that would appeal to any coach. But from Schiano’s perspective, saving 8.97% a year in taxes may be the sweetest plum of all.


[i] Given the high price he could command for running camps, speaking engagements, etc… additional income of $600,000 per year is probably a reasonable estimate

[ii] after accounting for the federal benefit for the state taxes paid to New Jersey.

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OK, perhaps I was a bit harsh yesterday when I compared life as a CPA to serving hard time. For fear that I may have dissuaded any impressionable readers from pursuing a potentially rewarding career in the field, allow me to highlight some of the advantages to becoming an accountant, starting with the undeniable fact that  — much like midget wrestlers and left-handed relief pitchers — accountants will always be in demand.    

If you don’t believe me, check out this list of the 6 Jobs to Watch in 2012,  on which accounting is firmly entrenched at #1. Take that, computer systems analysts!

Accountants are in especially high demand in April. But throughout the year, large firms require the assistance of public accountants to prepare, analyze, and verify financial documents. The Labor Department projects that more than 279,000 accounting positions will become available between 2008 and 2018.

As gratifying as that ranking may be, the accounting industry still has a bit of a “public perception” problem to overcome before it will ever be embraced for reasons other than its consistent demand. CPAs, it has long been my contention, are subject to more scorn and ridicule than any other profession in America, save for perhaps male nurses. We’re seen as Bob Cratchitt-types; complete with pale skin, thick glasses, and a healthy fear of our own shadow, conventional and tedious to the core, with the only thing less impressive than our sense of humor our aerobic capacity. While some may argue that this stereotype is too firmly entrenched in the collective conscience of the American public to ever be undone, I’d beg to differ.

As with most stereotypes, the one of the “geeky accountant” can be shattered simply through closer inspection. Throughout history, CPAs have run the gamut of the coolness meter. Consider these examples:

Clearly, being an accountant is not mutually exclusive with being a badass, regardless of popular opinion. There’s no reason you can’t crunch numbers, train for an Ironman, interpret the tax code, and lay down some hot licks on your guitar all in the same day. And while that race car driver gig you’ve always day-dreamed about might play better with the ladies, good luck finding a race car driver with a solid 401(k).

Of course, you could always just be a race car driver AND a CPA, like WS+B’s very own Rebecca Machinga:

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Yesterday was the unofficial start of “busy season” in the accounting world, which is every bit as depressing as it sounds. For the next few months we’ll be confined to our cubicles and deprived of sunlight and sound nutrition for days at a time; surviving only by adopting a singular focus on doing whatever it takes to make it until April 17th arrives to return our freedom. If busy season sounds a lot like a prison sentence, it’s because it is, only without all the free weights and shower shivvings.   

But if we’re gonna’ do it, we may as well do it right. To that end, throughout the next few months I’ll  touch on some commonly encountered tax compliance issues that are often misunderstood or misapplied. Today’s lesson: determining the deductible amount of mortgage interest when a taxpayer has total mortgage debt that exceeds the statutory limitations.

First, a primer on the limitations:

Since 1986, I.R.C. § 163(h)(3) has allowed a deduction for qualified residence interest for up to $1,000,000 of acquisition indebtedness and $100,000 of home equity indebtedness. Prior to amendment, the Code generally permitted a deduction for qualified residence interest on debt that did not exceed the basis of the residence and the cost of improvements.

Questions have surrounded the continued relevancy of temporary regulations that were issued prior to the 1986 amendments. The IRS recently answered these questions  — albeit 25 years late — in Chief Counsel Memo 201201017. The memo holds the following:

  • A taxpayer may use any reasonable method, including the exact method and simplified method provided for in the temporary regulations, to determine the amount deductible as qualified residence interest when total debt exceeds the statutory limitations.
  • Regardless of which method is used, a taxpayer may allocate any interest in excess of the limited amounts in accordance with the use of the proceeds under the interest tracing rules. Thus, if the excess proceeds are traced to use in a rental activity, the interest can be deducted on Schedule E; if they were used to purchase investments, the interest may be deductible on Sch. A as investment interest, and so on…

If those bullets make perfect sense to you, lovely. If not, read on, as a detailed explanation and illustration follows.

The Temporary Regulations

The outdated temporary regulations[i] provided two methods for determining a taxpayer’s qualified residence interest when debt exceeded the applicable limitation: the simplified method and the exact method. Citing the legislative history of I.R.C. § 163, the IRS held in CCM 201201017 that a taxpayer can also use any reasonable method to allocate debt in excess of the $1,100,000 limitation. An example of any reasonable method would be the method used in the worksheet found in Publication 936.

Simplified Method

Under the simplified method, interest on all debts is multiplied by the following fraction to determine the maximum deductible amount  :  $1,100,000/ the sum of the average balances of all secured debts.[ii]

To illustrate, assume you owned a home secured by the following debts: First mortgage: $900,000; Home equity line: $300,000; Second mortgage: $150,000.

Assume the home equity line was used for personal expenses and the second mortgage was used entirely in your rental real estate business. If the total interest expense on all three mortgages for 2011 was $80,000, using the simplified method the maximum amount of interest deductible on Schedule A as qualified residence interest would be: $80,000 * $1,100,000/$1,350,000 = $65,185.

Under the temporary regulations, if you used the simplified method you were required to treat interest on all excess debt as nondeductible personal interest. Thus, you would not be permitted to deduct any of the remaining interest in excess of the $65,185 computed above, even though the proceeds of the second mortgage were used in a rental activity. In perhaps the most important piece of CCM 20120107, however, the IRS ruled that a taxpayer using the simplified method can, in fact, apply the interest tracing rules to any interest expense in excess of the limited amount.

Exact Method

Under the exact method, the amount of qualified residence interest is determined on a debt-by-debt basis by comparing the applicable debt limit for the debt to the average balance of each debt. The applicable debt limit is an amount that is equal to the $1,000,000 limit on qualified residence debt reduced by the average balance of each debt that was previously secured by the qualified residence.

If the average balance of the debt does not exceed the limitation for that debt, all the interest on that debt is qualified residence interest. If the average balance of the debt exceeds the limitation, the amount of qualified residence interest is determined by multiplying the interest with respect to the debt by a fraction, the numerator of which is the applicable debt limit for that debt and the denominator of which is the average balance of the debt.

Applying the same facts as above, the applicable debt limit for the $900,000 first mortgage would be $1,000,000, and the entire interest expense related to the debt would be deductible. The applicable debt limit for the $250,000 debt would be $100,000 ($1,000,000 – $900,000), and 10/25 of the interest expense would be deductible as qualified residence interest. The interest on an additional $100,000 of the $250,000 debt would be deductible as home equity interest. Lastly, the applicable debt limit for the second mortgage of $150,000 would be $0, as the entire $1,000,000 limitation has been used.

Under the exact method, a taxpayer is also permitted to treat interest on debt that exceeds the limitations according to the use of the debt proceeds under the interest tracing rule. Thus, though the interest on the remaining home equity line of $50,000 would not be deductible — as it was used for personal expenses — the interest on the $150,000 second mortgage would be deductible as trade or business interest under the interest tracing rules.


[i] Treas. Reg. § Section 1.163-10T

[ii] Prior to the amendment, this numerator was the adjusted purchase price of the residence.

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Ed note: If you received an email earlier today, please disregard. I had a case of premature publication. It’s embarassing, but it happens, and I’m not ashamed to admit it.

In response to increased scrutiny regarding the effective tax rate paid on his substantial income, Republican Presidential candidate Mitt Romney released his tax returns late last night. Yours truly was given an opportunity to review the returns immediately upon their release for Bloomberg and provide comment. You can read that article here, but in the interest of keeping this blog self-contained, the most revealing items included in Romney’s 2010 individual tax return are discussed below:

  •  His real name is Willard? I’d go with Mitt, too.
  • Romney paid $3,000,000 of federal tax on $21,600,000 of gross income, for an effective rate of 13.9%. While this is sure to draw ire from the 99-percenters, it is 100% legal, and is largely attributable to two things:
  1. Romney’s $18,000,000 of alternative minimum taxable income (he paid a small amount of AMT)  consisted of $15,500,000 of income eligible for the preferential tax rate of 15%. In specific, $3.3M of Romney’s $4.7M of dividend income was eligible to be taxed at this lower rate, a break that was added to the Code with the Bush tax cuts. In the absence of the Bush legislation, Romney’s entire $4.7M of dividends would have been taxed at the maximum ordinary income rate, currently 35%. In addition, Romney’s also recognized $12.2M of long-term capital gains, which similarly benefitted from the Bush cuts. The gains are currently taxed at 15% rather than the 25 or 28 percent rates that existed previously.
  2. As expected, Romney benefits greatly from the current treatment of “carried interest” as provided for under administrative rulings issued by the IRS. In short, a carried interest is a partnership interest granted to a partner — typically a money manager in a private equity firm — in only the future profits of the partnership in exchange for managing the money of the private equity firm, choosing its investments, divestitures, etc… Under Rev. Procs. 93-27 and 2001-43, the granting of a pure profits interest is not a taxable event; thus, when Romney receives a profits interest in a private equity firm, it is not taxed as compensation (or capital gain), and the future income of the private equity partnership that is allocated to him — typically long-term capital gains — is eligible for the preferential 15% rates.

The reason carried interests have come under attack — particularly from the Obama administration — is obvious. On the surface, the amounts allocated to the managing partner certainly appear to be compensation for services; thus, according to critics, they should be taxed at ordinary income rates rather than capital gain. While this law may change in the future, it is important to note that Romney is completely correct in treating the amount of income allocated to him from his carried interests — $7,000,000 of the total $12,200,000 of capital gain according to his campaign — as LTCG rather than compensation.

  • Of Romney’s $3,000,000 of charitable contributions, half were made in cash to the Church of Latter Day Saints (which would appear to be part of Romney’s tithing requirement), and half made in stock to Romney’s private foundation, the Tyler Foundation.
  • How bad were things in 2009 if even Mitt Romney had a $4,000,000 capital loss carryforward to 2010?

All in all, there as nothing shocking about Romney’s tax returns. Yes he paid only 13.7% of his income to the IRS in federal tax, but such is life under the current tax regime when the overwhelming majority of your income is earned in the form of long-term capital gains and qualified dividends. Critics, however, are sure to focus on four things:

  1. The effective rate. Again, for right or wrong, Romney paid only 13.7% of his income in tax, but he did so legally and in total compliance with the current rules.
  2. The pure size of the numbers. Even for a Presidential candidate, $20M of AGI is a lof to income, which may not be particularly well received in this time of the Occupy Wall Street movement, cries of economic inequality, and other opening salvos of class warfare.
  3. Romney received a $1.6M tax refund in 2010. Now you and I know that tax refunds are purely a function of your tax liability compared to the estimated payments you’ve made, but the public is likely to find it hard to swallow that someone with $20M of income received a refund exponentially larger than most people’s income for the year. Again, it’s not the right reaction, but it’s likely to occur.
  4. Prior to the release of his returns, Romney admitted to a 15% effective rate, stating that he did generate some ordinary income from speaking fees, but “not much.” It turns out “not much” was in excess of $500,000, a sum most would be more than happy to accept for a few hours of speaking. This could position Romney as “out of touch” with the average American, an angle many of his critics and opponents may embrace.

Additional coverage:

The Washington Post

The NY Times

CBS News

Wall Street Journal

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As a young CPA, I had tremendous difficulty grasping the difference between a taxpayer’s “effective” tax rate and his “marginal” tax rate. Of course, I also have tremendous difficulty grasping how Twitter works, so perhaps I’m not the best barometer for this sort of thing.

But if you find yourself similarly challenged, this piece from the USA Today may help end the confusion. The impetus for the article is the recent hubbub surrounding Republican Presidential candidate Mitt Romney’s admission that he paid a tax rate of approximately 15% on his millions of taxable income. As the author points out:

Under the United States’ progressive tax system, income is taxed at graduated rates. An individual’s tax bracket, sometimes referred to as the marginal tax rate, refers to the percentage of income that’s taxed at the top tax rate — not the rate for the entire amount. (Ed note: this marginal rate is often referred to as the tax rate imposed on the last dollar of taxable income earned.) The effective tax rate, meanwhile, is the amount a taxpayer pays in taxes as a percentage of total income.

Thus, assume Romney earned $500,000 in speaking fees and $5,000,000 in long-term capital gains from his role as a retired partner in Bain Capital. While Romney’s marginal tax rate would be 35%, as his income level reaches the highest tax bracket, the fact that the overwhelming majority of his taxable income qualifies for the preferential tax rate on capital gain means his effective tax rate would approximate 15%.

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A few things you may have missed while watching Lee Evans and Kyle Williams let the Super Bowl slip between their fingers.

Some key numbers to have handy during individual filing season.  The most important one?  It’s only 85 days until April 17th.

Despite the fact that the federal deficit is growing faster than Kobe’s divorce settlement, the IRS is cutting agents. Did you know that based on a 2,080-hour work year, cutting one senior corporate auditor would cost the U.S. $19 million in lost revenue.  If I were a senior corporate auditor, I’d totally use that factoid to pick up chicks.

Obama would like to see the U.S. corporate tax rate lowered, but its reach extended.  He should make sure to leave a reminder on a  Post-it note for the new guy. HI-YO!

Speaking of unpopular Presidents, the Bush tax cuts apparently made the rich richer and the poor poorer. Odd. I would have thought the lower and middle classes — what with their expansive stock portfolios – would have stood to benefit the most from reduced capital gains rates.

If you’re over 70 1/2, pull yourself away from that Murder She Wrote  marathon on AMC long enough to check out this article, reminding you that your ability to make a contribution from your IRA directly to a charity without generating taxable income is gone. For now.

Lastly:    Wooderson + Butch Walker = Awesomeness. That’s just science.

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