Attorney-at-Law

THEY DIDN’T LISTEN TO ME

In Uncategorized on 06/21/2014 at 02:58

Treasury and the IRS, I mean. Why am I not surprised?

I’m talking about the now-adopted amendments to Circular 230. Here’s the whole ball of wax:

http://www.irs.gov/pub/irs-utl/TD_9668_6-9-14_Cir%20230_6-9-14_Final_Reg.pdf

See my blogpost “Comments to Circular 230 Revisions”, 11/12/12, so I won’t have to rehash here what I said there.

I still think I am right, but that hardly matters. Read and heed the new slippery-slope rules. I will continue to use a warning legend in my marketed opinions, and the new regulations do not prohibit that, at least.

They’re dead wrong about §10.82, and its distinction between annual and more-often-than-annual filings. It’s unfair to lump the two, and all the talk about “showing disregard” ignores the fact that sixteen months is a lot less than thirtysix months. Again, see my blogpost.

There’s too much emphasis in the preamble on saving money, with assumptions drawn from the thinnest of air and calculations worthy of a façade easement appraisal, and not enough on practical in-the-field experience.

OK, I’m annoyed, and that’s a poor frame of mind in which to be writing a blogpost, especially at 3 a.m. local time.

So I’ll close with Abraham Lincoln’s words. “I do the very best I know how – the very best I can; and I mean to keep doing so until the end. If the end brings me out all right, what’s said against me won’t amount to anything. If the end brings me out wrong, ten angels swearing I was right would make no difference.”

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