Attorney-at-Law

I WISH I WERE HOMEWARD BOUND

In Uncategorized on 08/27/2013 at 21:13

On tour this week with the IRS Nationwide Tax Forum, I post here a rare personal reflection.

Echoing Paul Simon’s 1965 hit, I’m sitting in the National Harbor Gaylord Resort Hotel, with a railway ticket to my destination, but with two more days of CPE (gotta get those hours) ahead.

And I’m bored.

I’ve got no gripe with the lectures or the lecturers, but the 2013 tax law changes have lost their novelty, the Affordable Care Act has become this year’s l’Affaire Dreyfuss (take a look at that splendid Caran d’Ache cartoon “they spoke of it”), and there’s not a lot new with SFRs and ASFRs, and preparer penalties.

There is a new Form 8938 Statement of Foreign Assets to go with 1040s, and FBARs are now all going to be filed electronically, but that has been circulating for a while on the IRS website. Moreover, discussions of tax forms are not what I do best.

And Tax Court, the source of my blogposts, today has two pedestrian T. C. Memos only, and no interesting orders.

One reiterates yet again the TFRP rule that the entity’s liability has nothing to do with the responsible person’s obligation to remit the withheld funds, even when the entity bears the intriguing title of Hey Baby Enterprises, Inc. The case is Pamela L. Lengua, 2013 T. C. Memo. 197, filed 8/27/13, but the corporate name is the best part of the case.

Next is an old protester trying to relitigate his 1991 loss, and getting yet another Section 6673 jab from that usually welcoming, but now unsympathetic, jurist Judge Lauber. I pass.

So this evening I again turn to Mr. Simon: “But all my words come back to me/ In shades of mediocrity.”

I wish I were homeward bound.

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