Tax Blog/Blawg

Back in the era of beepers, being "on call" evoked imagery of importance.  Indeed, those people required by their job to carry a beeper, along with those who did so voluntary, displayed the devices with a noticeable degree of smugness.  The positive aspects of this status symbol aside, anyone who has been obligated to carry a beeper or its modern equivalent (e.g., BlackBerry, iPhone, PalmPilot, etc.) understands that being constantly reachable is often more of a curse than a blessing.

Many jobs mandate that a person respond to messages within a certain period of time, minimize travel so ...

Editors’ note.  This is the first of a new periodic series on the Tax Blawg.  Mainstream press articles often implicate complex, technical tax issues.  Admirably, the press attempts to simplify the tax issues to make them more interesting and digestible for the general public, but sometimes simplification can leave readers with an incomplete or misleading understanding of the big tax picture.  For that portion of the audience who wants a little more background than the mainstream press can realistically provide, this series will unwind the tax issues discussed in prominent news ...

Two weeks ago, the Fifth Circuit summarily rejected a taxpayer request for an en banc rehearing in Southgate Master Fund LLC v. United States.  The appellate court had previously concluded that the taxpayer was not entitled to a claimed capital loss from a transaction involving the acquisition of distressed debt via a partnership because the partnership was a “sham” that should be disregarded for federal tax purposes.  The taxpayer's petition for rehearing, along with two amicus briefs, raised the specter that the Fifth Circuit's opinion would require taxpayers to have a non-tax ...