Guest Article

The Jeffrey Winick tax story is about one of the simplest methods of not paying taxes. That simple method of not paying is simply not paying. Winick is a very successful real estate broker specializing in retail leases. The company he founded, Winick Realty (now rebranded RTL), has in the past been listed as one the top five of retail brokers in New York City. As far as my friend Grok can discern, Winick managed all this with no formal education beyond high school. That makes it extra impressive. I identify with him just a bit. He grew up in Kew Gardens Hill, Queens, New York, and is 75 years old. I also grew up not far from Manhattan and am 74. I sometimes fantasize about living in Manhattan. He's living there, and apparently he was really living. His lifestyle was a major topic in the litigation.

I'm almost nostalgic for the days of 2021-2022, the COVID-induced tsunami of Tax Court filings and cases. This month we've seen only eight T. C. Memos, of which two were routine undocumented deduction cases (Section 6001 or Section 274), no Sum. Ops, and no T. C.s. It's been years since practitioners murmured the old, nearly-forgotten slogan as they booked their summer vacations: "File in May and go away," but it may be time again. Here's what happened.

It is painful when you finally realize that the money you expected to be repaid is never coming back. The tiny silver lining in that cloud might be the tax benefit of “writing off” the debt. Unfortunately, that silver lining may well be eclipsed by an even bigger cloud. Writing bad debt off is not that easy, and there’s probably no silver lining to that cloud. Ironically, you might find that the mistakes that caused you to be holding a bad debt might be what prevents you from getting a usable deduction.

Setting up a partnership is a lot like getting married. It's exciting, full of promise, and if you do it right, it can be incredibly rewarding. Do it wrong, and you're setting yourself up for years of headaches and potentially significant financial loss. The decisions you make at the formation stage of your partnership will impact your tax situation for years to come, and in some cases, these decisions can be difficult or costly to undo later. In this article, we'll explore the critical steps in setting up a partnership and the tax implications of various contribution strategies. You'll learn how to establish a foundation that maximizes tax advantages from day one.

There has never been a moment in the accounting profession, quite like this one. For decades, new tools have promised efficiency and accuracy, but artificial intelligence is different. AI is not just another tool, it’s a change in how we work. AI can automate tasks that were formerly part of our everyday work, such as data entry, reconciliations, reporting, and even initial research.

The Fifth Circuit Court of Appeals opinion in Sirius Solutions L.L.L.P. v. Commissioner may change our views of entity choice. If the decision holds up, partnerships will be able to effectively make the portion of limited partner income subject to self-employment tax whatever they want, including zero. This contrasts with the IRS position upheld by the Tax Court in Soroban Capital that treated all of the income of limited partners who were active in the business as self-employment income.

For many accountants, narrowing our focus can feel risky. We are trained to serve anyone who needs help and provide stability in any financial situation. Choosing a niche often raises concerns: Will we turn away good clients? Will we limit opportunities or reduce business stability? These are common doubts many of us have faced in our careers.

April brings both anomalies and the same-old from Tax Court. Congressional enactments that misfire give opportunities to inventive practitioners, while self-represented petitioners continue to do the darndest things. All these are teaching moments that make "the small court" a continuing professional education course that never ends.