An Authority even more exalted than the IRS or even the United States Tax Court used the above-set-forth phrase to describe a choice taken.
A couple months back (hi, Judge Holmes), I mentioned a brief exchange with my colleague Peter Reilly, CPA, concerning IRS’ offer to nonpetitioning Dixieland Boondockers to come out with hands up and buy peace. Each of us had his own take on whether or not the IRS schema was overly sweet, or thorns lurked among the roses. See my blogpost “VRBO? – Not Quite,” 7/15/24.*
I await the exact terms of any effected settlement. Perhaps Mr. Reilly or another member of the trade press or blogosphere will pull a couple Forms 7249 Offer Acceptance Report, so those terms will be made public.
Meantime, petitioned cases are settling out. So, by way of comparison when we get the terms of nonpetitioners’ settlements, here’s Wisawee Partners II, LLC, E. Ronald Martin, Jr., Tax Matters Partner, Docket No. 6015-18, filed 10/18/24.
50% charitable claimed for year at issue $4,332,000. Allowed $0. Other deduction (K-1, line 13d) claimed $300,911. Allowed $1,373,421. So got about 30% at close of play.
Can’t wait to see if a nonpetitioner chose the better part in their deal with Danny Werfel.
And I lose some more blogfodder. The summary J the Wisawees were seeking back in ’22 is mooted out. See my blogpost “Another Silt-Stir,” 1/7/22.**
Taishoff Law 