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Monday, August 11, 2014

The IRS Scandal, Day 459

TaxProf Blog Weekend Roundup

Sunday, August 10, 2014

NY Times: A Corporate Tax Break That’s Closer to Home

New York Times:  A Corporate Tax Break That’s Closer to Home, by Gretchen Morgenson:

Rage is rising over American corporations that chop their tax bills by acquiring entities in lower-tax countries. Medtronic, AbbVie and Mylan have all announced such plans — known as inversions — in recent months. And Walgreen was poised to relocate to Switzerland after it completes its purchase of Alliance Boots, but did an about-face last week in the face of widespread denunciation.

Some in Congress have proposed legislation to shut the door on this tax-savings tactic. But across town at the Internal Revenue Service, officials have recently opened the window to another. They did so in a ruling disclosed late last month by Windstream Holdings, a telecommunications company based in Little Rock, Ark.

The ruling allows Windstream to spin off its copper and fiber network into a real estate investment trust, or REIT. That sounds pretty ho-hum until you realize it means that Windstream won’t have to pay hundreds of millions of dollars in taxes. ...

How did the I.R.S. conclude that a telecom network is a real estate asset? As with all things tax-related, the details are somewhat complicated. ...

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August 10, 2014 in Tax | Permalink | Comments (0)

Byrnes: Charity and the Jurisprudential Lessons from History

William Byrnes IV (Thomas Jefferson), The Development of Charity: Jurisprudential Lessons from History:

This article describes the ancient legal practices, codified in Biblical law and later rabbinical commentary, to protect the needy. The ancient Hebrews were the first civilization to establish a charitable framework for the caretaking of the populace. The Hebrews developed a complex and comprehensive system of charity to protect the needy and vulnerable. These anti-poverty measures, including regulation of agriculture, loans, working conditions, and customs for sharing at feasts, were a significant development in the jurisprudence of charity.

The article begins with a brief history of ancient civilizations, providing context for the development of charity by exploring the living conditions of the poor. The second half of the article provides a searching analysis of the rabbinic jurisprudence that established the jurisprudence of charity. This ancient jurisprudence is the root of the American modern philanthropic idea of charitable giving exemplified by modern equivalent provisions in the United States Tax Code.

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August 10, 2014 in Scholarship, Tax | Permalink | Comments (0)

Top 5 Tax Paper Downloads

The IRS Scandal, Day 458

Saturday, August 9, 2014

Princeton and Wellesley May Re-inflate Grades

P-WPrinceton and Wellesley are considering reversing actions they took a decade ago to curb grade inflation:  Princeton capped A-range grades at 35%, and Wellesley imposed a mandatory B+ median in introductory (100) level and intermediate (200) level courses with at least 10 students:

Princeton, Report from the Ad Hoc Committee to Review Policies Regarding Assessment and Grading:

Princeton

Wellesley, The Effects of an Anti-Grade-Inflation Policy at Wellesley College:

Wellesley

 Wellesley

Update:  The Economist, What the Ivies Can Learn From Wellesley

August 9, 2014 in Legal Education | Permalink | Comments (6)

Retirement of John Dean, First African-American Tax Court Judge

John F. Dean has retired after twenty years as a Special Trial judge on the U.S. Tax Court.  He was the first African-American Judge on the Tax Court.

Tax Court Logo 2b. Washington, District of Columbia. Graduated, B.S., Michigan State University, 1970; Columbus School of Law; J.D., Catholic University of America, 1975; M.L.T., Georgetown University Law Center, 1985. Admitted to District of Columbia Bar, 1975, Supreme Court of the United States, Federal District Courts, Northern District of Texas, District of Maryland, and United States Tax Court. Employed by the Office of Chief Counsel for the Internal Revenue Service, Dallas District Counsel, 1975-78; Baltimore District Counsel, 1978-86; Office of Associate Chief Counsel, International, 1986-94. Adjunct Professor of Law, Howard University, 1999 to present; Vice Chair, Judicial Counsel of the Washington Bar Association, 2002-03. Appointed Special Trial Judge, United States Tax Court, on August 7, 1994.

August 9, 2014 in Tax | Permalink | Comments (0)

Robert Redford Sues New York Over $1.6 Million Tax Bill; Can State Tax Nonresident on Sale of Interest in Nonresident LLC?

The IRS Scandal, Day 457

IRS Logo 2George Will, The Reason for Watergate:

June 17, 1971, was four days after The New York Times began publishing the leaked "Pentagon Papers," the classified Defense Department history of U.S. involvement in Vietnam. Nixon worried that further leaks would reveal his role in sabotaging negotiations that might have shortened the war. This fear caused Nixon to create the "the plumbers" and to direct an aide to devise other proposals such as the one concerning Brookings. This aide suggested using the IRS against political adversaries, but added:"The truth is we don't have any reliable political friends at IRS. ... We won't be ... in a position of effective leverage until such time as we have complete and total control of the top three slots at IRS." Forty years later, the IRS has punished conservative groups, and evidence that might prove its criminality has been destroyed. Happy anniversary.

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August 9, 2014 in IRS News, IRS Scandal, Tax | Permalink | Comments (2)

Friday, August 8, 2014

Weekly Tax Roundup

Weekly Roundup

August 8, 2014 in Tax, Weekly Tax Roundup | Permalink | Comments (0)

Weekly Legal Education Roundup

August 8, 2014 in Legal Education, Weekly Legal Education Roundup | Permalink | Comments (0)

Weekly SSRN Tax Roundup

August 8, 2014 in Scholarship, Tax, Weekly SSRN Roundup | Permalink | Comments (0)

Weekly Student Tax Note Roundup

August 8, 2014 in Scholarship, Tax, Weekly Student Tax Note Roundup | Permalink | Comments (0)

NY Times, WSJ Disagree Over Obama's Authority to Stop Corporate Inversions

New York Times Dealbook:  How Obama Can Stop Corporate Expatriations, for Now, by Victor Fleischer (San Diego):

The Obama administration has broad legal authority to stop corporate inversions.

Professor Stephen E. Shay recently published an article in the trade journal Tax Notes, calling on the Obama administration to take unilateral action to impede the surge of tax-motivated corporate expatriations without waiting for Congress to pass new legislation. Professor Shay, a professor of practice at Harvard Law School and former deputy assistant secretary for international tax affairs at the Treasury Department, argued that the Treasury Department has the legal authority to reduce the incentives to give up United States citizenship. This could be done, he said, by limiting the deductions for interest payments that an American subsidiary pays its foreign parent company, and by ensuring that profits of overseas subsidiaries will continue to be subject to American taxes. ...

Robert Willens, an influential tax commentator, dismissed Professor Shay’s article in a bulletin to clients as merely “interesting reading with little, if any, practical significance.” Mr. Willens noted that Treasury has never been able to set workable regulations under Section 385 of the tax code, one of the key sections Professor Shay suggested as legal authority. Mr. Willens also explained that rules limiting interest deductions may cause some consternation among the nation’s trading partners. “If these weapons were so readily available,” he concluded, “it stands to reason that they would have already been utilized.”

The dispute boils down to law versus politics. There is no question that Professor Shay gets the law right. To be sure, there are limits on what the Treasury Department can do. It is limited in its ability to define who is, and who is not, a United States corporation; those rules are fixed by statutory language. But Professor Shay has nudged the Treasury to focus on related legal questions — what constitutes debt versus equity, and what is the definition of United States property under Section 956 — where the law is unclear and the Treasury Department has broad authority to interpret those rules in a manner consistent with the legislative framework of the tax code. ...

Of course, it is possible that Mr. Willens has the politics right. The fact that the Obama administration has the legal authority to change the incentives of inversions does not necessarily mean that it will. It must consider the reaction of Britain and our other trading partners. It should think about whether investors have settled expectations about deals that have already been announced. But I see no obvious reason that the Treasury Department should feel constrained by these political issues.

Wall Street Journal editorial, Obama's Tax Law Rewrite: Where's the Law That Gives Jack Lew the Power to Raise Taxes?:

Let's focus today on tax inversions, which allow corporations to relocate overseas in a way that reduces their tax liability. Mr. Obama has conceded these are legal, and as recently as July 16 Mr. Lew told CNBC that "we have looked at the tax code. There are a lot of obscure provisions that we do not believe we have the authority to address this inversion question through administrative action. If we did, we would be doing more."

But lo, on Tuesday a spokeswoman announced that Treasury "is reviewing a broad range of authorities for possible administrative actions" to limit inversions "as well as approaches that could meaningfully reduce the tax benefits after inversions take place."

Hello? That sure sounds like rewriting tax law by executive fiat, which violates the Constitution's separation of powers. The rewrite is all the more legally suspicious since no one at Treasury or the Justice Department seems to have been aware of this power before Mr. Obama began denouncing the "unpatriotic tax loophole." From where does Mr. Lew derive this power to act like a one-man Ways and Means Committee? ...

[A]n [Office of Legal Counsel] precedent is directly relevant to tax policy. President George H.W. Bush campaigned in 1988 on cutting the capital-gains tax, but Democratic Majority Leader George Mitchell used a filibuster to block it in the Senate as the economy stumbled.

As Mr. Bush sought re-election in 1992, these columns urged him to use what we believed was his unilateral authority to index the capital gains tax for inflation—a way to boost the economy by other means. Our legal argument was that the term "cost" as written by Congress in the tax code is ambiguous and doesn't mean the "purchase price" of a stock as interpreted in Treasury regulations.

The White House counsel's office wrote a lengthy memo explaining Mr. Bush's legal power to do this. But the Treasury's legal department disagreed, the Justice Department was asked for its opinion, and the OLC lawyers sided with Treasury. Mr. Bush declined to act, the economy took longer to recover, and Bill Clinton won the 1992 election.

So now we have a President in an election year looking for a way to raise taxes on corporations after he couldn't get Congress to agree. Has anyone asked Treasury's career lawyers or the Office of Legal Counsel? Someone should. And when the next President arrives in 2017, one of his first acts should be to release publicly all of the OLC memos making the legal case for Mr. Obama's many illegal acts, assuming there are any.

August 8, 2014 in Tax | Permalink | Comments (0)

Council of the ABA Section on Legal Education Meets Today

ABA Logo 2The Council of the ABA Section on Legal Education and Admission to the Bar meets today in Boston:

Open Session Agenda

A. June 2014 Open Session Minutes

B. Review and Approve Revised Internal Operating Practices (IOPs)
1.  Revised IOPs
2.  Explanation of Revisions

C. Report on Standards Transition Plan

D.  Budget
1.  Consider revised budget, based on ABA budget outcome, hiring, revision to travel budget, technology and set school fees

E. Affiliate Reports
1.  AALL
2.  ALWD
3.  CLEA
4.  LSAC
5.  NALP Update
6.  NALP Class of 2013 Selected Findings
7.  NCBE
8.  SALT

F. Data Policy Committee Report (Strickman)
1. Minor adjustments to AQ
2. Beta testing of employment outcomes protocol

G. Rport on Student Loans Forgiveness Work Group

H. Committee Reports
1.  BOG Liaison
2.  Law Student Division
3.  Young Lawyers
4.  House of Delegates
5.  Managing Director
6.  Chairperson

August 8, 2014 in ABA Tax Section, Legal Education | Permalink | Comments (0)

1911 College Rankings (U.S. Government Edition)

Chronicle of Higher Education, How Did the Federal Government Rate Your College a Century Ago?:

1911As Vox’s Libby Nelson notes in a chronicle of the 1911 ratings, the Association of American Universities actually asked the government to devise them. Kendric Charles Babcock, the top higher-education official in the U.S. Bureau of Education, itself a division of the Interior Department, undertook the task. Few were happy with the result. (Anyone surprised?) President William Howard Taft later killed it.

So how did your college stack up more than a century ago? A few things to keep in mind: The four tiers of colleges were based on how prepared their graduates were for graduate school. Also, the asterisks in Class II were used to distinguish its stronger colleges, the equivalent of a “plus” in a paper grade.

1

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August 8, 2014 in Law School Rankings, Legal Education | Permalink | Comments (1)

94% of Academic Economists Admit to Unacceptable Research Practices, Including Sex for Co-authorship and Promotion

Inside Higher Ed, Sex, Lies, Economists:

SLVA small proportion of European economists have confessed to “acceptance or offering of sex” in exchange for co-authorship or promotion, as well as owning up to fabricating or manipulating data.

A survey of about 400 economists, conducted among members of the European Economic Association on an anonymous basis, is analyzed in the article Scientific Misbehavior in Economics, currently in press for the journal Research Policy.

Ninety-four percent of respondents reported having engaged in at least one “unaccepted research practice,” the paper says.

London School of Economics, Scientific Misbehavior in Economics: Unacceptable Research Practice Linked to Perceived Pressure to Publish:

Almost every economist reports having engaged in at least one practice considered unacceptable by peers. For example, one third of the participants admit to having cherry-picked results – the selective presentation of empirical results that confirm one’s argument is rejected by 84%. Even though 64% consider it unacceptable to divide one’s work into small units to maximize the number of publications, 20% confess salami slicing. Strategic behavior in the publication process is considered unjustifiable by two thirds. However, 39% admit that they have taken into account suggestions of referees or editors even though they thought that they were wrong. Even 60% report that they have cited strategically to raise publication prospects.

research practice

August 8, 2014 in Legal Education, Scholarship | Permalink | Comments (1)

The IRS Scandal, Day 456

Thursday, August 7, 2014

Kleinbard: 'Competitiveness' Has Nothing to Do With Inversions

Edward D. Kleinbard (USC), 'Competitiveness' Has Nothing to Do With It:

The recent wave of corporate tax inversions has triggered interest in what motivates these tax-driven transactions now. Corporate executives have argued that inversions are explained by an "anti-competitive" U.S. tax environment, as evidenced by the federal corporate tax statutory rate, which is high by international standards, and by its "worldwide" tax base. This paper explains why this competitiveness narrative is largely fact-free, in part by using one recent articulation of that narrative (by Emerson Electric Co.’s former vice-chairman) as a case study.

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August 7, 2014 in Scholarship, Tax | Permalink | Comments (2)

Oei & Ring: Human Equity? Regulating the New Income Share Agreements

Shu-Yi Oei (Tulane) & Diane M. Ring (Boston College), Human Equity? Regulating the New Income Share Agreements:

A controversial new financing phenomenon has recently emerged. New “income share agreements” (“ISAs”) enable an individual to raise funds by pledging a percentage of her future earnings to investors for a certain number of years. These contracts, which are offered by entities such as Fantex, Upstart, Pave, and Lumni, raise important questions for the legal system: Are they a form of modern-day indentured servitude or an innovative breakthrough in human financing? How should they be treated under the law?

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August 7, 2014 in Scholarship, Tax | Permalink | Comments (0)

Desai: Tax Withholding, Statutes and Constitutional Law

Anuj C. Desai (Wisconsin), What a History of Tax Withholding Tells Us About the Relationship between Statutes and Constitutional Law, 108 Nw. U. L. Rev. 859 (2014):

In this Article, I explain what a seemingly obscure statute, the Current Tax Payment Act of 1943, can tell us about the relationship between statutes and constitutional law. I use William Eskridge and John Ferejohn’s notion of a “superstatute” as a lens through which to view this relationship. A “superstatute,” in Eskridge and Ferejohn’s conception, is a statute that has small “c” constitutional emanations, emanations that both affect interpretations of the large “C” Constitution and are entrenched against subsequent legislative change. To better understand the precise contours of the notion of a superstatute, I look at the Current Tax Payment Act of 1943, which instituted the system of federal tax withholding for wage income. I describe the history of federal income tax withholding leading up to the passage of that Act, explaining in turn how that history sheds light on the underlying notion of a superstatute.

August 7, 2014 in Scholarship, Tax | Permalink | Comments (0)

Tenured Florida A&M Prof Sues Law School, Claiming Gender Discrimination in Pay

Tampa Tribune, FAMU’s Law School Hit with Discrimination, Unequal Pay Lawsuit by Female Professor:

Florida AM LogoJennifer Smith, an associate professor hired in 2004, ... accuses [Florida A&M Law School] of eight violations of federal and state law on equal pay and gender discrimination, her suit says. She seeks unspecified damages, a promotion to full professor, attorney fees and other relief.

Her complaint says the law school “consistently hired men at considerably higher rates than women,” with male associate professors “paid considerably more” than females. Smith says she was granted tenure in 2010, but has been repeatedly turned down for promotion to full professor ever since, starting that same year.

Smith’s complaint says that an administrator “sabotaged” her promotion by replacing the good recommendations in her file with bad ones and then called other university officials to further torpedo any promotion. She says her treatment was in part retaliation for submitting public record requests to the school for professor-pay information.

Her complaint also reveals she lodged a workplace-violence complaint against the same administrator, saying that person “made some threatening comments about her.” Smith’s complaint quotes from a September 2012 ABA report on the law school that cited faculty concerns about an “inhospitable environment for women, lesbians and gay faculty members.”

August 7, 2014 in Legal Education | Permalink | Comments (4)

Nebraska 'Sovereign Citizen' Convicted of Filing False Liens Against Federal Officials and Federal Tax Crimes

U.S. Department of Justice press release, Nebraska “Sovereign Citizen” Convicted of Filing False Liens Against Federal Officials and Federal Tax Crimes:

DOJ Logo (2013)A federal jury in Omaha, Nebraska, found Donna Marie Kozak guilty on Friday of conspiracy to file and filing false liens against two U.S. District Court judges, the U.S. Attorney for the District of Nebraska, two Assistant U.S. Attorneys and an Internal Revenue Service (IRS) special agent, the Justice Department announced.

The federal jury also convicted Kozak of filing a false claim against the United States for $660,000 and for corruptly endeavoring to obstruct the due administration of the internal revenue laws.  Kozak was remanded into custody pending sentencing.  The maximum prison term for each false lien charge is 10 years,  five years for the false claim charge and three years for the obstructing the IRS charge.  Many of the offenses have an additional 10 years of potential imprisonment because they were committed while Kozak was on pretrial release.

Based on the evidence introduced at trial and court filings, Kozak, a former member of the so-called sovereign citizen group “Republic for the united States of America,” engaged in a conspiracy to retaliate against federal officials involved in the criminal investigation and prosecution of David and Bernita Kleensang, associates of Kozak who were convicted of federal tax crimes in 2012.  Kozak initially retaliated against the federal judge who presided over the Kleensang trial by filing a false lien against her for $19 million with the Boyd County, Nebraska, clerk’s office.  After a federal grand jury indicted Kozak for filing the false lien and for federal tax crimes, she filed five $18 million false liens against federal officials at the Washington County, Nebraska, register of deeds office while on pretrial release.

The evidence introduced at trial and court filings also showed that since the late 1990s, Kozak has engaged in a long series of fraudulent schemes to obstruct the internal revenue laws.  These included placing her property in sham trusts, establishing a sham charitable foundation, sending harassing correspondence to IRS employees and filing bogus tax returns, trust returns, private-foundation returns and other false documents with the IRS.  In 2008, she filed a tax return based on fictitious income and tax withholdings on Form 1099-OID statements that claimed a refund of $660,000.

Above the Law, Tax Fraud, Tax Protestors, and the Most Awesome Willfulness Doctrine in Federal Criminal Law Today

August 7, 2014 in IRS News, Tax | Permalink | Comments (0)

Taylor: Closing the Gap Between Private Letter Rulings and Regulations

Tax Analysys Logo (2013)Willard Taylor (Sullivan & Cromwell & NYU), Closing the Gap Between Private Letter Rulings and Regulations, 144 Tax Notes 597 (Aug. 4, 2014):

In this article, Taylor summarizes and comments on proposed regulations that would redefine real property for real estate investment trusts, and he argues that there should be more (and earlier) guidance on these and similar issues to close the gap between private letter rulings and published guidance affecting REITs and publicly traded partnerships in the natural resources sector.

August 7, 2014 in Scholarship, Tax, Tax Analysts | Permalink | Comments (0)

Seto Reviews Tahk's Public Choice Theory & Earmarked Taxes

JotwellTheodore P. Seto (Loyola-L.A.), An Empirical Test of Public Choice Theory (Jotwell) (reviewing Susannah Camic Tahk (Wisconsin), Public Choice Theory & Earmarked Taxes, 68 Tax L. Rev. ___ (2015)):

In 1980, James Q. Wilson, in The Politics of Regulation, predicted that laws with diffuse costs and concentrated benefits would be relatively easy to enact, but that laws with concentrated costs and diffuse benefits would be relatively hard to enact and, once enacted, hard to maintain. This hypothesis, one of the pillars of public choice theory, has long been asserted without empirical verification. ...  In Public Choice Theory & Earmarked Taxes, Susannah Camic Tahk provides the first rigorous empirical support for Wilson’s hypothesis.

Her study explores the histories of 1497 state-level earmarked taxes between 1997 and 2005. Earmarked taxes, in general, produce more concentrated benefits than taxes the proceeds of which flow into a state’s general fund. Thus, we would expect earmarked taxes to perform strongly as revenue generators. And, indeed, Tahk finds that the earmarked taxes in her sample raised 58.39% more revenue in 2005 than in 1997—a larger percentage increase than any major federal tax over the same period. ...

It is hard to overstate the importance of this accomplishment.

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August 7, 2014 in Scholarship, Tax | Permalink | Comments (1)

Death of Cynthia Beerbower

Dayton Daily News Obituary:

Cynthia Gibson Beerbower passed away on July 26, 2014, in her South Kensington home in London. She was 65. ...

Cynthia received her BA, magna cum laude, from Mount Holyoke College in 1971, her JD from Boston University Law School in 1974 and her LLB from the University of Cambridge in 1976. At Cambridge, she was a member of Newnham College. She married John E. Beerbower in 1971. John, a 1966 graduate of Oakwood High School and also a panelist of the Dayton Daily News Youth Forum the year ahead of Cynthia, became a partner at the law firm of Cravath, Swaine & Moore in New York City in 1980.

After admission to the New York Bar, Cynthia was an associate at the New York City law firm of Simpson, Thacher & Bartlett, where she was elected a partner in 1981. She specialized in tax. At the time, she was one of only a handful of women partners at Wall Street law firms. In 1993, she joined the first Clinton administration, serving first as International Tax Counsel under Secretary Lloyd Benson and then as Deputy Assistant Secretary for Tax Policy under Secretary Robert Rubin. She left government service in late 1996.

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August 7, 2014 in IRS News, Obituaries, Tax | Permalink | Comments (0)

Cooper & Ivimey: 2013 Developments in Connecticut Trusts & Estates Law

Jeffrey A. Cooper (Quinnipiac) & John R. Ivimey (Reid and Riege, Hartford), 2013 Developments in Connecticut Estate and Probate Law, 88 Conn. Bar J. ___ (2014):

This Article provides a summary of recent developments impacting Connecticut estate planning and probate practice. Part I discusses 2013 legislative developments. Part II surveys selected 2013 case law relevant to the field.

August 7, 2014 in Scholarship, Tax | Permalink | Comments (0)

The IRS Scandal, Day 455

IRS Logo 2National Review:  No, the IRS Did Not Target Progressives Like It Targeted Conservatives:

NPR’s politics blog has published a chart — compiled from a House Ways and Means staff analysis — of the different levels of IRS targeting between conservative and progressive groups. Bottom line? Far more conservative groups faced IRS scrutiny, they faced more questions, and were approved at a much lower rate than progressives. The chart is based on the IRS’s now-discredited “BOLO” (be on the lookout) lists.

Chart 1

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August 7, 2014 in IRS News, IRS Scandal, Tax | Permalink | Comments (0)

Wednesday, August 6, 2014

Record Numbers of Americans Are Renouncing Their U.S. Citizenship

International Tax Blog:  2014 Second Quarter Published Expatriates, by Andrew Mitchel:

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2014.  The number of published expatriates for the quarter was 576.  The number of published expatriates for the first half of 2014 has been 1,577 (1,001 + 576).  Last year there was a record setting 2,999 published expatriates.

Renounce

(Hat Tip: Laura Saunders.)

August 6, 2014 in Tax | Permalink | Comments (3)

Pittsburgh Tax Review Publishes New Issue

Pittsburgh Tax Review The Pittsburgh Tax Review has published Vol. 11, No. 2 (Spring 2014):

August 6, 2014 in Scholarship, Tax | Permalink | Comments (0)

Infanti: The House of Windsor: Accentuating the Heteronormativity in the Tax Incentives for Procreation

Anthony C. Infanti (Pittsburgh), The House of Windsor: Accentuating the Heteronormativity in the Tax Incentives for Procreation, 89 Wash. L. Rev. ___ (2014):

Following the Supreme Court’s decision in United States v. Windsor, many seem to believe that the fight for marriage equality at the federal level is over and that any remaining work in this area is at the state level. Belying this conventional wisdom, this essay continues my work plumbing the gap between the promise of Windsor and the reality that heteronormativity has been one of the core building blocks of our federal tax system. Eradicating embedded heteronormativity will take far more than a single court decision (or even revenue ruling); it will take years of work uncovering the subtle ways in which heteronormativity pervades our federal tax laws and of identifying means of eliminating that heteronormativity. To further this work and in keeping with the theme of this symposium issue, “Compensated Surrogacy After Windsor,” this essay explores the unremitting heteronormativity of the federal tax incentives for procreation as they apply to compensated surrogacy, which is the only practical option for gay couples wishing to procreate.

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August 6, 2014 in Scholarship, Tax | Permalink | Comments (0)

Taxpertise: Murder, Mayhem, Romance, Comedy and Tax Tips, For Artists Of All Kinds

Bonnie Lee (IRS Enrolled Agent), Taxpertise: A Novella For The Creative Mind -- Murder, Mayhem, Romance, Comedy and Tax Tips, For Artists Of All Kinds (2014):

TaxpertiseYou've heard of starving artists. Many of them are starving because they fork out too much money in taxes. And why does that happen? Because most artists hate numbers and consequently don't deal with them too well. I was asked to write a tax book specifically for artists but my first thought was, "Would anyone actually read it?" I pictured artists with insomnia purchasing this book as a sleep aid. Yet there is so much valuable information that can help whose who hate numbers and keep more dollars in their pockets that I was forced to rethink the approach so I can reach out and help them. And so I chose a format that would be entertaining: a Novella.

Kim Stillwell is a single, gorgeous, 34-year-old tax professional. When Luke Hunter, a rock musician, becomes a client, her heart goes into a spin! It's love at first sight, but she doesn't trust her feelings. While preparing his tax returns and organizing his home office, she remains professional, yet the romantic stirrings continue and seem to be reciprocated. Then the murder of Dominic Rodriguez, Luke's previous bookkeeper, throws their budding romance into mistrust and turmoil.

Follow their adventures and gain valuable knowledge through the tax tips offered at the end of each chapter. Even those have a humorous edge!

August 6, 2014 in Book Club, Tax | Permalink | Comments (0)

A Field Study of a Fat Tax and its Unintended Consequences

Brian Wansink, Andrew S. Hanks, John Cawley & David Just (all of Cornell), From Coke to Coors: A Field Study of a Fat Tax and its Unintended Consequences:

Fat TaxCould taxation of calorie-dense foods such as soft drinks be used to reduce obesity? To address this question, a six-month field experiment was conducted in an American city of 62,000 where half of the 113 households recruited into the study faced a 10% tax on calorie-dense foods and beverages and half did not. The tax resulted in a short-term (1-month) decrease in soft drink purchases, but no decrease over a 3-month or 6-month period. Moreover, in beer-purchasing households, this tax led to increased purchases of beer. To behavior scholars, this underscores the importance of investigating unexpected substitutions. To public health officials and policy makers, this presents an important empirical result and more generally points toward wide ranging contributions that marketing scholarship can make in their decisions.

August 6, 2014 in Scholarship, Tax | Permalink | Comments (0)

Christians: Regulating Return Preparers -- A Global Problem for the IRS

Tax Analysys Logo (2013)Allison Christians (McGill), Regulating Return Preparers: A Global Problem for the IRS, 75 Tax Notes Int'l 391 (Aug. 4, 2014):

The IRS is in charge of a juggernaut of a tax system, the likes of which there truly is no equal in the world. And as all too often appears to be the case, in the enthusiasm to improve the functioning of this regime, its authors and enforcers appear to have forgotten that this unique system is perfectly global in reach, thanks to its unique inclusion of citizens and others with legal residence status no matter where in the world they live.

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August 6, 2014 in Scholarship, Tax, Tax Analysts | Permalink | Comments (0)

Tahk: Public Choice Theory and Earmarked Taxes

Susannah Camic Tahk (Wisconsin), Public Choice Theory & Earmarked Taxes, 68 Tax L. Rev. ___ (2015):

The Article draws on public choice theory to argue that the manner in which the federal income tax distributes its costs and its benefits undergirds the massive fiscal crises that the federal government is now experiencing. Then, this Article offers recent historical evidence on 1500 state-level taxes to develop a way out of the current tax lawmaking paralysis at the federal level. At present, the federal income tax spreads its benefits widely among large yet diffuse groups, which makes the income tax easy to undermine and difficult to improve. The Article proposes, however, that restructuring the manner in which the federal income tax allocates its costs and benefits can circumvent its self-destructive shortcomings. For this purpose, state-level tax laws offer useful templates. In particular, states "earmark" tax revenues for specific purposes. That arrangement gives rise to fundamentally different tax lawmaking dynamics than those operating at the federal level. To understand how and why these dynamics succeed, the Article presents evidence on the cost-benefit structure of all state-level earmarked taxes from the 1997-2005 historical period. Analysis of this evidence demonstrates that how state-level earmarked taxes laws assign their costs and benefits relates to how revenue-productive and durable these tax laws are. This conclusion furnishes federal tax policymakers with a promising way of revising the federal income tax code to overcome its current defects. The analysis also opens new lines of research at the neglected intersection of public choice theory and scholarship on legal reform.

August 6, 2014 in Scholarship, Tax | Permalink | Comments (0)

More Tax Inversion News

Bloomberg News, Obama Let Delphi Avoid Taxes in Tactic President Assails, by Zachary R. Mider:

President Barack Obama says U.S. corporations that adopt foreign addresses to avoid taxes are unpatriotic. His own administration helped one $20 billion American company do just that.

As part of the bailout of the auto industry in 2009, Obama’s Treasury Department authorized spending $1.7 billion of government funds to get a bankrupt Michigan parts-maker back on its feet -- as a British company.

August 6, 2014 in Tax | Permalink | Comments (4)

How UC-Berkeley and UCLA Law Schools Responded to Ban on Affirmative Action

Inside Higher Ed, How Berkeley and UCLA Law Schools Responded to Ban on Affirmative Action:

UCA new study from the National Bureau of Economic Research [Danny Yagan (UC-Berkeley), Affirmative Action Bans and Black Admission Outcomes: Selection-Corrected Estimates from UC Law Schools] explores the impact of California's ban on consideration of race in admissions on admissions rates for black students to the law schools at the University of California at Berkeley and UCLA. The study finds a significant drop in the black admit rate -- from 61 to 31 percent, controlling for various factors. The 31 percent figure, the study finds, is still significantly higher than it would have been had the law schools focused largely on traditional admissions criteria such as test scores and grades, and the advantage for black applicants is greatest among the share of the applicant pool that is on the line between admission and rejection. The study suggests that the UC law schools have minimized the loss of black students by placing greater emphasis in admissions on race-neutral factors (such as economic disadvantage) that apply to many black applicants. Officials of the two law schools said that they were studying the report and could not comment on it Monday.

Table 1

Cheating: An Insider's Report on the Use of Race in Admissions at UCLA

August 6, 2014 in Legal Education, Scholarship | Permalink | Comments (1)

The IRS Scandal, Day 454

IRS Logo 2National Review:  The IRS's God Complex:

Is the Internal Revenue Service a threat to religious liberty?

As the IRS continues to come under well-aimed fire for harassing conservative groups, on Friday it secured a final court order formalizing what amounts to a secret agreement to monitor the pulpits of ill-favored churches. The serious danger, as former Justice Department attorney J. Christian Adams told Fox News, is that the IRS will start treating “theology as politics,” and regulate it accordingly.

Lovers of liberty should be very concerned.

According to a June 27 IRS letter to the Justice Department, 99 churches merit “high priority examination” for allegedly illegal electioneering activities. The letter was sent in reference to a now-dismissed lawsuit filed by the atheist group known as the Freedom from Religion Foundation (FFRF). The suit originally was a rather broad one, demanding not only that the IRS enforce prohibitions against churches’ endorsing candidates specifically, but also that churches should be “required to file” what it described as “detailed annual information” that would force them (if they are like other nonprofits) to “expend substantial time and resources.”

With the end of the suit, those filings presumably will not be required (though a second suit, on just that subject, remains open). But IRS’s monitoring of alleged electioneering activities could still be quite onerous.

Traditionally, churches have been free to do just about anything short of outright candidate endorsements. Conservatives have suggested that not even that prohibition is enforced against traditionally liberal churches in black communities and that FFRF isn’t much concerned with such groups. But at least for conservative-leaning churches, FFRF has a much more restrictive agenda in mind. ...

FFRF has been crowing loudly about its “victory.” It asked for its suit to be dismissed “without prejudice” because the IRS was able to assure FFRF, in private discussions, that the agency would indeed take an active role in monitoring churches. That’s what the IRS’s June 27 letter to the DOJ, which specified that 99 churches warrant “high priority examination,” explained.

In fact, the IRS on July 22 filed a motion with the court specifically to deny the request of another church, which had become a party to the suit, for documents pertaining to the “agreement” between IRS and FFRF. In other words, shockingly, the IRS was now taking the side of the atheist group that had nominally sued it. One week later, FFRF filed a motion making clear, as its co-president Annie Laurie Gaylor put it, that the dismissal of its suit applies only if “our agreement has teeth.”

So even though the IRS will now put “teeth” into its monitoring of churches, the general public will not be allowed to find out exactly what those teeth can bite into (according to the IRS’s July 22 motion against release of documents, which the judge granted August 1).

Considering the IRS’s well-publicized penchant for burying or erasing evidence (even from Congress) of its bias against conservative political groups, this secrecy about enforcement teeth in the church-electioneering case should raise concerns from every traditionalist church and faith group.

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August 6, 2014 in IRS News, IRS Scandal, Tax | Permalink | Comments (2)

Tuesday, August 5, 2014

S&P: Income Inequality Is Hampering Economic Growth

New York Times:  A New Report Argues Inequality Is Causing Slower Growth. Here’s Why It Matters., by Neil Irwin:

S&P 2Is income inequality holding back the United States economy? A new report argues that it is, that an unequal distribution in incomes is making it harder for the nation to recover from the recession and achieve the kind of growth that was commonplace in decades past.

The report is interesting not because it offers some novel analytical approach or crunches previously unknown data. Rather, it has to do with who produced it, which says a lot about how the discussion over inequality is evolving.

Economists at Standard & Poor’s Ratings Services are the authors of the straightforwardly titled "How Increasing Inequality is Dampening U.S. Economic Growth, and Possible Ways to Change the Tide.” The fact that S&P, an apolitical organization that aims to produce reliable research for bond investors and others, is raising alarms about the risks that emerge from income inequality is a small but important sign of how a debate that has been largely confined to the academic world and left-of-center political circles is becoming more mainstream.

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August 5, 2014 in Tax | Permalink | Comments (0)

Board Waives $100 Penalty for Taxpayer Who Refused to Pay Taxes Electronically Due to Fear of Computer Hacking

Haar v. Commissioner of Revenue, No C3115058 (Mass. App. Tax Bd. July 23, 2014):

HackingThis appeal involves the Commissioner’s assessment of a $100 penalty ... because of the appellant’s failure to electronically submit the payment that accompanied his Form-4868, Application for Automatic Six-Month Extension of Time to File Massachusetts Income Tax Return for the tax year at issue.  ...

Mr. Haar maintained that the Commissioner’s electronic payment mandate is a “serious invasion of both [his] privacy and [his] personal business practices,” as it exposes his finances to risk of cyber attack. On his abatement application, Mr. Haar explained, “I intentionally do no electronic banking nor direct bill paying, I have none of my credit cards linked to my bank accounts directly and I think anyone who does any of the above is exposing themselves to multiple risks of cybercrime and identity theft.” At the hearing, Mr. Haar testified that he does not link his “bank account information in any electronic way to any other electronic medium” because he believes it is a “very foolish thing to do.” Mr. Haar further expressed doubts as to the security of the computer systems used by the Department of Revenue (“DOR”), noting that “if the Pentagon can be hacked,” he had little confidence that DOR could protect his – or any other taxpayer’s – personal data from theft. ...

The Board found credible the appellant’s testimony that he was concerned that transmitting his personal financial information electronically would expose him to a serious risk of security breaches. Given his reference to the hacking of the Pentagon’s computer systems, and in light of the many well publicized instances of large-scale thefts of financial information following computer security breaches at businesses and other institutions, and the appellant’s consistent practice of avoiding electronic payment of all of his bills, including his tax obligations, the Board found that the appellant’s failure to utilize the Commissioner’s mandated electronic tax payment to be reasonable.

For more, see Forbes:  State Fails To Force Electronic Payments On Taxpayer With Hacking Concerns, by Peter J. Reilly.

August 5, 2014 in Tax | Permalink | Comments (0)

Sad News From Vermont Law School

HannaCheryl Hanna, Vice President for External Relations and Professor of Law at Vermont Law School, took her own life last week at the age of 48, leaving behind a husband and two children. Professor Hanna's family has requested that, in lieu of flowers, memorial contributions be made in her memory to Women Helping Battered Women, P.O. Box 1535, Burlington, VT 05402.

ShieldsFormer Vermont Dean Geoffrey “Jeff” Benson Shields died on August 2 at the age of 68.   His family asks that any gifts in his memory be sent to the Hallowell Singers, 191 Canal St., Brattleboro, Vt. 05301, or to The Jeff and Genie Shields Prize at Vermont Law School, 164 Chelsea St., South Royalton Vt. 05068. A week before his death, Dean Shields and his wife gave their family home to the law school:

“Jeff and Genie have given to this school in so many remarkable ways over the years—their extraordinary and dedicated service to students, faculty, staff and alumni during Jeff’s tenure as president and dean, their contributions to and relentless fundraising for the Center for Legal Services, and, of course, the establishment of the Shields Prize,” Mihaly and Board of Trustees Chairman Edward Mattes ’83 wrote in a letter to VLS faculty and staff. “The Shields have always led by example. This most generous gift is clear manifestation of [their] philanthropic spirit.” The historic 3,400-square-foot home, built in 1810, is currently for sale and rented by VLS students. The law school plans to continue the search for a buyer and have the students remain in residence for the duration of their lease.

August 5, 2014 in Legal Education, Obituaries | Permalink | Comments (3)

ABA Tax Section Seeks Pro Bono Tax Counsel

The ABA Tax Section seeks a Pro Bono Tax Counsel:

ABA Tax Section Logo (2012)The Pro Bono Counsel works closely with Tax Section members and staff to develop and grow pro bono programs for the Tax Section. Responsibilities include program development and management, advertising, writing and editing, and recruitment.

The Pro Bono Counsel also administers the Christine A. Brunswick Public Service Fellowship through the Public Service Fellowship Committee as well as the Janet Spragens Pro Bono Award through the Pro Bono Award Committee. The Pro Bono Counsel will cultivate relationships with the Tax Court, Armed Forces, IRS, the low income taxpayer community, Tax Section members, and other ABA entities.

Does substantive legal work and may manage a grant funded project or provide substantive support to an ABA entity. May manage that entity. May be supervised by another attorney and frequently supervises more junior attorneys and/or other staff. Includes legal research, writing, speaking, provision of technical assistance, and may include grant development and/or fundraising.

August 5, 2014 in ABA Tax Section, Tax, Tax Prof Jobs | Permalink | Comments (0)

Hawley: The Jurisdictional Question in Hobby Lobby

Erin Morrow Hawley (Missouri), The Jurisdictional Question in Hobby Lobby, 123 Yale L.J. Forum ___ (2014):

Hobby LobbyBurwell v. Hobby Lobby Stores may well be the biggest case of the term. And by its own rules, the Supreme Court lacked jurisdiction. An obscure statute, the Anti-Injunction Act of 1867 (“the AIA”), imposes a pay-first requirement for federal tax challenges. The deeply held conventional wisdom is that the AIA is a jurisdictional statute, and there is a good argument that the AIA applies to the contraception mandate. As we learned from National Federation of Independent Business v. Sebelius, 132 S.Ct. 2566 (2012), the best evidence of whether Congress intended the AIA to apply is the text. The mandate at issue in Hobby Lobby, 26 U.S.C. § 4980D, expressly refers to the employer assessment as a tax—24 times. In light of NFIB, the Supreme Court’s failure to address the AIA was a serious mistake.

(Hat Tip: Josh Blackman.)

August 5, 2014 in Scholarship, Tax | Permalink | Comments (0)

NPR Debate: Corporate Tax Inversions

NPR 2NPR -- The Diane Rehm Show, Debate Over Corporate Tax 'Inversions':


A growing number of American companies are re-incorporating overseas for lower tax rates. But critics say it’s a loophole that ends up costing taxpayers. Join us for debate over IRS rules for U.S. companies.

  • Edward Kleinbard (Professor of Law, USC)
  • Chris Edwards (Economist, Cato Institute)
  • John McKinnon (Reporter, Wall Street Journal)
  • Sander Levin (Ranking Member, House Ways & Means Committee)

August 5, 2014 in Tax | Permalink | Comments (0)

Joint Tax Committee Releases Tax Expenditure Estimates for 2014-2018

The Joint Committee on Taxation yesterday released Estimate of Federal Tax Expenditures for Fiscal Years 2014-2018 (JCS-97-14):

Joint Tax CommitteeTax expenditure analysis can help both policymakers and the public to understand the actual size of government, the uses to which government resources are put, and the tax and economic policy consequences that follow from the implicit or explicit choices made in fashioning legislation. This report1 on tax expenditures for fiscal years 2014-2018 is prepared by the staff of the Joint Committee on Taxation. ...  As in the case of earlier reports, the estimates of tax expenditures in this report were prepared in consultation with the staff of the Office of Tax Analysis in the Department of the Treasury (“the Treasury”).

The Joint Committee staff has made its estimates (as shown in Table 1) based on the provisions in Federal tax law enacted through June 30, 2014. Expired or repealed provisions are not listed unless they have continuing revenue effects that are associated with ongoing taxpayer activity. Proposed extensions or modifications of expiring provisions are not included until they have been enacted into law. The tax expenditure calculations in this report are based on the January 2014 Congressional Budget Office (“CBO”) revenue baseline and Joint Committee staff projections of the gross income, deductions, and expenditures of individuals and corporations for calendar years 2013-2018.

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August 5, 2014 in Congressional News, Tax | Permalink | Comments (0)

The Most Educated Places in America

NerdWallet, The Most Educated Places in America:

Certain cities in the U.S. have populations with higher levels of educational attainment than others. This often depends on what prominent industries are located in these places—cities that offer more technical occupational opportunities tend to draw more skilled and educated members of the labor force.

NerdWallet crunched the numbers to find the most educated places in America. We looked at increasing levels of educational attainment among the populations of 1,990 places across the U.S., from residents with at least a high school diploma to those with a doctorate or professional degree. ... We calculated the overall score for each place by weighting the following factors:

  1. Percentage of population with at least a high school diploma or associate’s degree: 40% of the overall score.
  2. Percentage of population with at least a bachelor’s degree: 30% of the overall score.
  3. Percentage of population with a master’s degree: 10% of the overall score.
  4. Percentage of population with a doctorate degree: 10% of the overall score.
  5. Percentage of population with a professional degree: 10% of the overall score.

Nerd

(Hat Tip: Bill Turnier.)

August 5, 2014 in Legal Education | Permalink | Comments (10)

Senate Finance Committee Unanimously Approves Tax Court Nominee Pugh

PughThe Senate Finance Committee on Friday unanimously approved the nomination of Cary Douglas Pugh to the U.S. Tax Court: (June 6, 2014):

Cary Douglas Pugh is currently Counsel in the tax department at Skadden, Arps, Slate, Meagher & Flom, L.L.P., a position she has held since 2005. From 2002 to 2005, Ms. Pugh was the Special Counsel to the Chief Counsel of the Internal Revenue Service. From 1999 to 2002, Ms. Pugh served as Tax Counsel for the Senate Committee on Finance, where she was responsible for advising committee members on individual and corporate tax issues. Ms. Pugh was an associate at Vinson & Elkins, L.L.P. from 1995 to 1999 and Judicial Clerk to the Honorable Jackson L. Kiser on the U.S. District Court for the Western District of Virginia from 1994 to 1995. Ms. Pugh received a B.A. from Duke University, an M.A. from Stanford University, and a J.D. from the University of Virginia School of Law.

Pugh will join the Tax Court once she is confirmed by the full Senate, along with pending nominees Tamara Ashford and L. Paige Marvel.

August 5, 2014 in Congressional News, Tax | Permalink | Comments (0)

Reynolds: Public Servants Acting as Public Masters

USA Today op-ed:  Public Servants Acting as Public Masters, by Glenn Reynolds (Tennessee):

"Nothing could be further from the truth. I mean, we wouldn't do that." That was CIA Director John Brennan's answer in March when Sen. Dianne Feinstein, D-Calif., charged the CIA with breaking into computers used by Senate investigators looking into CIA misconduct.

It turns out that the CIA would do that — and, in fact, had done so. Brennan's reassurances were false, and CIA spooks had been hacking into the committee investigators' computers looking for documents they thought the investigators shouldn't have, violating a promise not to. So, first Brennan broke a promise. Then, he either lied, or showed that he doesn't control his own agency, which in many ways would be worse.

Brennan has apologized, but his apology won't be the end of things. We're already seeing bipartisan calls for his removal, from Sens. Mark Udall, D-Colo., Martin Heinrich, D-N.M., and Sen. Rand Paul, R-Ky. The White House is hanging tough so far, but we're now hearing comparisons made to the speed with which Brennan's predecessor, Gen. David Petraeus, was cut loose over an extramarital affair. Does this mean that the White House views spying on, and lying to, members of Congress as less serious than an affair?

The answer to that, alas, is probably "yes." Contempt for Congress, and for separation of powers and historical understandings about the roles of the executive and legislative branches, has been a hallmark of the Obama administration. It's not surprising that in such an atmosphere, CIA operatives would feel comfortable snooping on the Senate, and that a CIA director would feel confident issuing blanket denials when questioned. ...

Alas, as with the IRS' stonewalling of investigations into its targeting of Obama's political opponents, consequences for offenders seem hard to come by in the face of an administration that has no shame. Probably the best that Congress can do is to punish the entire CIA by using its budgetary power to make employees' lives worse: Cutting back on bonuses, raises, conferences, and other perks. Where the IRS is involved, there's some talk of abolishing most of it in favor of a national sales tax that would require much less bureaucracy and provide fewer opportunities for abuse, but that's unlikely to go anywhere anytime soon.

The sad truth is that when you elect irresponsible people into positions of power, you get irresponsible government. President Obama oozes contempt for Congress, and for longstanding unwritten political accommodations among the branches, at every opportunity. It's unsurprising that his underlings feel — and act — consistently with that view.

If the American electorate votes more responsibly next time, things will get better. Until then, alas, elections have consequences, and this is one of them.

August 5, 2014 in IRS News, IRS Scandal, Tax | Permalink | Comments (0)

The IRS Scandal, Day 453

IRS Logo 2Washington Post:  Lois Lerner’s Conservative Bashing: Smoking Gun or Just Cause for Investigation?:

The Federal Eye received lots of feedback in recent days about an article analyzing the e-mails in which former Internal Revenue Service official Lois Lerner described conservative talk-show hosts as “__holes.”

In that piece, we noted that career federal employees are allowed to have political views, as long as those views don’t influence their work or affect elections. We also noted that Lerner’s comments represent only circumstantial evidence rather than rock-solid proof that she used her authority to silence conservatives.

Some readers objected to our rationale. ...

To be clear, the point of last week’s article was not to suggest that authorities shouldn’t investigate Lerner for potential wrongdoing. It was to say that Republicans haven’t proven definitively whether the former IRS official used her position to slow down the proliferation of conservative advocacy groups. ...

Did Lerner’s unit use inappropriate techniques to scrutinize such groups? The answer is yes, according to the agency’s inspector general, who said in a report last year that the IRS selected groups for review based on their names and policy positions.

The next question, then, is whether those actions were part of an effort to target conservative groups while going easy on left-leaning organizations. In other words, did Lerner’s political views — such as those expressed in her e-mails — cause her to become less than impartial in her work? ...

[M]any of the facts in this case look bad for Lerner. Her IRS division used inappropriate screening techniques that largely affected conservatives. She was a registered Democrat who used offensive terms to describe firebrand right-wingers. She expressed a desire to work for an advocacy group founded by President Obama’s allies. And she invoked her Fifth Amendment rights instead of testifying before Congress about her involvement in the targeting behavior.

Regardless, that’s all circumstantial evidence. It makes Lerner a prime candidate for investigation, and it’s great campaign fodder for the midterm elections, but it does not prove that she violated the rules of professionalism by trying to hinder conservative groups. Republicans need direct evidence to confirm that theory, which is part of the reason they want an independent prosecutor to look into the case. It’s also why they are so frustrated with Lerner’s missing e-mails.

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August 5, 2014 in IRS News, IRS Scandal, Tax | Permalink | Comments (1)