Islander

And that’s what saved the day. Unfortunately, the surge that saved the day came too late for Travis L. Sanders.

No, this surge had nothing to do with Iraq. This surge was the surge that Travis’ surge suppressor outfit was suppressing. The outfit threw off much money, funneled to Trav via his grantor trust’s interest in a Virgin Islands limited partnership, the kind that IRS described as a scam in IRS Notice 2004- 45, Meritless Filing Position Based on Sections 932(c)(4) and 934(b).

If that sounds familiar but you can’t quite place it, check out my blogpost “Catching Up”, 9/30/13, the ongoing saga of la famille Vento and their excursion to our Insolvent Islands in the Sun.

Trav entered into the usual employee leasing deal, dreamt up by VI tax whiz Marjorie Roberts, Esq., ex-Treasury maven for Virgin Islands Bureau of Internal Revenue (VIBIR). He gets VI CPA Scott Blair to do his taxes, and he files as a bona fide resident of VI for the years at issue.

Now when dealing with la famille Vento aforesaid, Judge Hardiman in Third Circuit set down the basic rules for VI residence, which gives escape from mainland taxation and bestows on that happy crew all the unguided largesse with which bona fide residents of those isles are favored.

But Trav went above and beyond, as the gamers say.

IRS claims Trav wasn’t a bona fide VI resident, but the four (count ‘em, four) lawyers on Trav’s side (plus one from the Virgin islands government, intervenor) suppress the five lawyers from IRS, and Judge Kerrigan rules the SOL bars IRS’s SNOD, because Trav filed properly with VIBIR per IRS’s confusing instructions and publication.

Trav “…maintained a checking account at Banco Popular de Puerto Rico in St. Thomas, USVI. The address for the checking account was a USVI address. Decedent reported his residence as St. Thomas, USVI, on his license and certificate of marriage. Decedent was married in the USVI….. [Trav] had bank accounts with UBS Financial Services, Inc., in the USVI and First Bank in St. Thomas in the USVI. [Trav’s] checks for his First Bank account showed a USVI address as his address.” 144 T. C. 5, at p. 9.

So marrying a Virgin (Islander) really helps the cause.

But Trav doesn’t show up for the victory party. Trav died while the case was pending, so we have Estate of Travis L. Sanders, Deceased, Thomas S. Hogan, Jr., Personal Representative, Petitioner, and the Government of the United States Virgin Islands, Intervenor, 144 T. C. 5, filed 1/29/15.