In Uncategorized on 03/23/2017 at 17:00

From an earlier part of this famous speech, IRS, “If you have tears, prepare to shed them now.”

Tax Court, per Judge Lauber, has unloaded upon you 188 pages, demolishing your twelve (count ‘em, twelve) lawyers under a barrage of eighteen (count ‘em, eighteen) lawyers, in Amazon.Com, Inc. & Subsidiaries, 148 T. C. 8, filed 2/23/17.

There’s also about seventeen pages of CVs, for the expert witnesses.

If you think I’m going to digest this, when I’ve sworn off drink for the rest of the month, try again.

But I will say that IRS is thoroughly pummeled as arbitrary, capricious and unreasonable. The Comparable Uncontrolled Transaction (CUT) is extolled, the mysterious “Project Goldcrest” (see my blogpost “Carousel,” 6/9/14) is unveiled, obeisance is paid to Altera (see my blogpost “Sixteen Lawyers – Part Deux,” 7/27/15, for stock-based compensation, although that’s up on appeal to 9 Cir.), and $234 million in deficiencies is sent off for a Rule 155 beancount that should shrink the deficiencies like an icicle in a blast furnace.

Ya think Amazon will cut the cost of my Prime membership?

  1. […] best comment in the rest of the coverage came from Lew Taishoff, who declined to dig in deep to the […]


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