tag:blogger.com,1999:blog-1519969502186924526.post2358652411546982324..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: Other Players in “Abusive” Tax SheltersJack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger4125tag:blogger.com,1999:blog-1519969502186924526.post-32236787389524473282009-07-27T12:30:31.188-05:002009-07-27T12:30:31.188-05:00Mr. / Mrs. Anonymous: Prof. Chirelstein is not a ...Mr. / Mrs. Anonymous: Prof. Chirelstein is not a hack lawyer nor is he a lier. Whether or not he is wrong is even debatable. I believe he is wrong. But, then, whether or not I am wrong in believing him wrong is debatable. More directly to the point, whether or not you are wrong is debatable. The purpose of this blog is to engage in discussions of substance. At hominem attacks do not further the discussions of substance.Jack Townsendhttps://www.blogger.com/profile/14469823736335455874noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-945398925821722632009-07-26T09:44:37.450-05:002009-07-26T09:44:37.450-05:00Mr. Townsend, I am well aware of your record in th...Mr. Townsend, I am well aware of your record in this area and my comments were certainly not directed at you but rather the hack lawyers who seem to so easily dismiss and in my view lie about the law in this area like Chirelstein.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-87681861518258905772009-07-25T13:33:45.820-05:002009-07-25T13:33:45.820-05:00It appears that anonymous has an agenda that goes ...It appears that anonymous has an agenda that goes beyond the topic discussed in the blog. Professor Chirelstein's premise is that the shelters were blatantly illegal. I just wanted trace down where the premise takes one logically.<br /><br />I did note that I disagree with the premise, so perhaps Anonymous and I would head in the same direction once we move away from the premise. I did not want to do that in this blog because I wanted to keep the focus.Jack Townsendhttps://www.blogger.com/profile/14469823736335455874noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-19170316183405559262009-07-25T09:40:18.524-05:002009-07-25T09:40:18.524-05:00What does blatantly illegal even mean? Most of th...What does blatantly illegal even mean? Most of the shelters involved where real investments with a chance of profit and under the case law at least through 2002 that was enough to at least get to MLTN. What about Fulcrum Financial Partners where the DOJ gave Ted Turner over $80 million in tax deductions through a settlement approved by the court from a tax shelter which via judicial admission the DOJ and the IRS held the shelter was a sham with no opportunity for profit? What about Sala which won in court yielding a $60 million deduction from a transaction that had little chance of profit? What about ACM where the judge held the tax shelter lacked economic substance because in the last 10 years interest rates had never moved enough to generate profits and it was unreasonable to contend rates ever would move enough even under dire circumstances? What about Gitlitz where the SC held a literal reading of the law trumped the generic economic substance argument? I would submit any tax lawyer who ignores the cases favorable to tax shelters is committing malpractice and should be disbarred. Especially liars and thieves like Mike Hamersley who not only participated in devising and approving tax shelters but then went on to turn his very own clients in to the IRS, DOJ and Senate for such shelters claiming he had no involvement and now the dude has the audacity to practice a s a tax lawyer, anyone who uses him bares the risk he will turn them in for fraud on strategies he works on, very nice.Anonymousnoreply@blogger.com