In Uncategorized on 01/11/2016 at 14:11

I certainly wasn’t mentioned in dispatches in those long-ago days, when my wardrobe largely consisted of green fatigues (into which I could not now fit). But’s ace tax blogger, Peter Reilly, CPA, has lately undertaken to redress that omission by soliciting an extensive quote from me.

You can read it at

I omitted to blog the Gemperle opinion (2016 T. C. Memo. 1, filed 1/4/16), because it really said nothing new. Mr. Reilly seemed upset that the Gemperles were barred from offering into evidence their appraisal, which document apparently never got attached to their return. And of course the appraiser who authored that document wasn’t around to be cross-examined on the trial.

Well, what price Joseph Mohamed, Jr. and Shirley Mohamed, 2012 T. C. Memo. 152, blogged by me under the caption “Pay Me Now or Pay Me Later,” 5/29/12. Joe’s and Shirl’s $20 million charitable land donation got bounced because no appraisal was attached to their return. Why not? Joe and Shirl were following the misleading instructions in that year’s iteration of Form 8283, that’s why not. And this, notwithstanding the land was clearly worth at least what Joe and Shirl claimed on the trial it was worth.

Of course, Joe and Shirl prepared their own return. One can only wonder, with that much moolah on the cliché, why Joe and Shirl didn’t have a brigade of CPAs and an armored division of appraisers on the deal.

Granted, the Gemperles were small stuff. And maybe the CPA who prepared their return was dead when the trial came on.

For my rant about the landmarkers leading property owners down the proverbial by promising tax breaks to pay off the property owners, so that the landmarkers don’t have to pay, see Mr. Reilly’s blogpost abovecited.

This is a steadfastly non-political blog.



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