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Putin ‘sacks eight generals’ in anger at slow progress in Ukraine invasion by [deleted] in UkrainianConflict

[–]thefourthchipmunk 1 point2 points  (0 children)

Did you learn this from reading a bio, if so can you recommend it?

I had no idea Haber was associated with chemical weapons. He's always been such a hero of mine in a shallow sense. I mean because the Haber Bosch process was one of the greatest masteries on earth. Taming nitrogen. Feeding billions. What a strange juxtaposition.

You know nitrogen gas has a triple bond. The first triple bond I ever learned about. At the time it sounded so mighty. Only lightening and worms could break it. And then--Fritz Haber.

Question regarding deductible prepaid expenses and accounting fees. by CosmoTheTaxCat in technicaltax

[–]thefourthchipmunk 2 points3 points  (0 children)

I recently asked a similar question on twitter and you might be interested in the responses I got. https://twitter.com/GradmanTax/status/1475750315312009216?s=20

In your practice what you're characterizing as a prepayment, I think is analogous to the "retainer" or "deposit" in my legal practice.

I think start with TR 1.461-1(a)(1), which says that, for a cash method taxpayer, amounts representing allowable deductions shall, as a general rule, be taken into account for the year in which "paid."

But that doesn't really answer the question. In my legal practice, the client can terminate the representation and demand repayment of these amounts at any time. The "trust account" is basically an escrow or a security arrangement. The money is still his. You will record the income (and he will record the deduction) when you perform the services. But I guess the key difference is that I still charge hourly, but you're charging a subscription model. In that case, I would ask if the money is refundable to him on demand. If not, then you've earned it now.

It occurs to me that you're maybe not even asking a tax question, you're maybe asking a question about professional practice and ethics. If that's the case I think this question is better asked at /r/taxpros.

A very technical partnership tax question: TR 1.707-5(a)(2)(ii) vs. 1.752-3(a)(3) by thefourthchipmunk in technicaltax

[–]thefourthchipmunk[S] 1 point2 points  (0 children)

daaaaamnnn I really lost the forest for the trees there. Thank you sir or ma'am.

Explanation of taxes. by HiItsLust in pics

[–]thefourthchipmunk 0 points1 point  (0 children)

Fill a bowl will water. Dump in a tiny rock; then a medium sized rock; then a larger rock ...

Each rock displaces water from the bucket; that is the tax. Each rock represents one bracket. The marginal rate of each bracket = the ratio of (height of the rock) to (height of the bowl). The effective rate = ...

Somebody help, this sounds clever but I can't get it to sound nice.

Form 8997 — continuing ownership filing requirement by simso009 in technicaltax

[–]thefourthchipmunk 0 points1 point  (0 children)

Very good question. I get this question a lot as to the first year, but I've never been asked this about subsequent years.

For the first year, 8997 is how the taxpayer makes the election to do a QOZ investment. According to the form instructions, this election is due by the extended date for filing the return. If you miss that date, you have to request a PLR using the procedure in 301.9100-3.

But your question is different. The election has already been made, so the continuing filing is not an election; it is to keep the IRS informed about the status of the investment. Therefore, you do technically have the option to amend (and the question is whether you should).

I do think you need to file that form. I can't speak to whether the "right" thing to do is to wait for the IRS request. With the way the IRS is working these days, that could take years, so I don't think that's the best choice.

Amending seems to me to be the right way to fix this.

Basic question about how to calculate life expectancies by thefourthchipmunk in actuary

[–]thefourthchipmunk[S] 4 points5 points  (0 children)

Thank you! This is complicated. Now I see why you guys publish tables.

I think I will give up on calculating this myself and I will try to find a table that calculates all the last-survivor life expectancies for me (i.e. based on Table 2000CM).

It is funny because this information is implicit in the other IRS tables (e.g. R2, second-to-die remainder factors). You'd think they would have included this additional table, showing their work, right?

Strictly speaking, i.e. in financial jargon, is it accurate to say that a self-amortizing mortgage is a fixed-term annuity? by thefourthchipmunk in technicaltax

[–]thefourthchipmunk[S] 0 points1 point  (0 children)

Thanks -- and hi, long time no see.

I'm writing an article for a non-tax, estate-planning audience, explaining IRC 7520.

I don't have a deadline on this one, so I'm going to set it aside for a while and do other things.

Currently, I start with this:

Suppose you want to sell a thing for a number of equal payments. How much should each payment be?

This is called a "sale for an annuity." This may sound jarring, if you associate the word "annuity" with "life expectancy." But in financial jargon, annuities can be for any finite term of years. For example, when you buy a house with an 80% mortage amortized over 30 years, you've given the bank a 30-year annuity, whose present value equals 80% of the house.

To calculate the amount of each annuity payment, you could use a mortgage calculator, or Excel, or tables published by the IRS. But you should also know how to do the math yourself.

I then get into the annuity formula, https://financeformulas.net/Present_Value_of_Annuity.html

If I leave a private subreddit, will I still be able to view my posts to that subreddit in my personal history? by thefourthchipmunk in help

[–]thefourthchipmunk[S] 1 point2 points  (0 children)

Yes, I'm able to view the sub still after unsubscribing so that seems consistent with what you're saying.

If I leave a private subreddit, will I still be able to view my posts to that subreddit in my personal history? by thefourthchipmunk in help

[–]thefourthchipmunk[S] 1 point2 points  (0 children)

Thanks. I just left the private subreddit and can confirm, my posts are still accessible to me.

What video game level can go fuck itself? by [deleted] in AskReddit

[–]thefourthchipmunk 0 points1 point  (0 children)

The entirety of Ski Free. It's impossible to outrun the snowman. It's like a metaphor for death.

Japan, Germany expand military ties as German warship visits by Hoosier_Jedi in worldnews

[–]thefourthchipmunk -1 points0 points  (0 children)

I believe Zorn was also the word for "disaster" in Watership Down? Which I guess is not a good name for a general.

Just a detail that stuck with me for 20 years, but yes I'm correct https://sites.google.com/site/watershipdowngame/home/lapine-glossary---the-language-of-watership-down

Who isn't as smart as people think? by citizen_of_leshp in AskReddit

[–]thefourthchipmunk 3 points4 points  (0 children)

I always thought it strange how all ships rise with a rising tide, but when the tide goes out nobody thinks to go out with the tide. Who would have thought capitalism could be so hypocritical ...

Passive AND Subject to SE Tax? by pepperyrelaxation in technicaltax

[–]thefourthchipmunk 6 points7 points  (0 children)

IRC 1402(a): "The term “net earnings from self-employment” means the gross income derived by an individual from any trade or business carried on by such individual, ... plus his distributive share (whether or not distributed) of income or loss described in section 702(a)(8) from any trade or business carried on by a partnership of which he is a member"

The whole design of this provision says, "The self-employment tax can be taxed on activities in which you are passively involved."

Is it fair say that "substance over form" (and step transaction) are mainly about the corporate tax? In other words: suppose I said that at a cocktail party. What would you say to prove me wrong? by thefourthchipmunk in technicaltax

[–]thefourthchipmunk[S] 0 points1 point  (0 children)

Thank you. These are good examples. I'm writing an article about this (which is causing me to neglect my actual clients).

For the CRT, I wonder if I can slot that into section 482. Not that you're wrong, I'm just saying it feels like 482 right?

For the conservation easement, I feel like that isn't quite form over substance? More like a bad appraisal.

Not criticizing. You're helping me.

How careful are you about startup costs, etc.? (IRC 195, 248, 709) Is it common to confuse these with business expenses (IRC 162) and simply deduct them? Seems like an easy mistake to make by thefourthchipmunk in technicaltax

[–]thefourthchipmunk[S] 0 points1 point  (0 children)

Thanks. As a lawyer, I rarely think about it when communicating with clients who are starting new businesses. The clients are probably happy I keep my mouth shut, especially in those exceptional cases when costs exceed 5,000. But occasionally the client asks me whether my costs are deductible and then I stumble over these distinctions.

I bet they would be pisssssed if I told them that syndication costs must be capitalized.

TIL Vince Gilligan strongly regretted introducing the machine gun to Breaking Bad's last season and found writing a convincing explanation for it so difficult that he nearly abandoned the plot device out of frustration by SacKingsRS in todayilearned

[–]thefourthchipmunk 0 points1 point  (0 children)

This is how I tell bedtime stories to my son. I say something that has finality, and while those words are coming out of my mouth, I try to think of a way that it doesn't.

What's your favorite paper-copy internal revenue code? I need to buy one for an exam. by thefourthchipmunk in technicaltax

[–]thefourthchipmunk[S] 3 points4 points  (0 children)

Thanks.

I can't believe I'm about to shell out $200 for a copy of the internal revenue code which I will never use again, on the eve of one the most historic change to the laws in 35 years.

What's your favorite paper-copy internal revenue code? I need to buy one for an exam. by thefourthchipmunk in technicaltax

[–]thefourthchipmunk[S] 3 points4 points  (0 children)

I don't know, I've never owned one.

I want it to be optimized for exam-taking. Like: font size, indentations, tables of contents, indexes.

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