The Curse of the Home Office

A home office is the work reality for many CPA consultants and tax preparers. It beckons with the promise of an easy commute, and the comfort of working in your pajamas. It provides the flexibility of working when you want to. It can also save thousands of dollars that would otherwise be spent on rent. What’s not to love?

Well, as tax preparer Joyce Linzy has learned the hard way, a home office can also be a liability. To recap the Tax Court decision in Linzy v. Commissioner, T.C. Memo 2013-219, Joyce Linzy felt harassed by client visits and calls at her home office, rented a hotel room to get away during the busy season, and attempted to deduct the cost of the hotel and travel as a business expense. The court ruled against Linzy (see To Sleep, Perchance to Dream (of Escaping Your Tax Clients).

As I read the case and the decision, a question formed in my mind: “How does one end up in this situation?”  Your home is your castle. How does your home office become a place to run away from? Here are three ideas to get you started on your way to a home office nightmare, guaranteed and fast!

1. Let your clients know that it is OK to stop by any time. No one will want to work with you unless you make yourself available 24/7. Besides, nothing is better for a professional image than a face to face meeting with your CPA making breakfast while wearing the above-mentioned pajamas!

2. Set up a shared phone line for your home and office. This step works even better if you don’t have caller ID and are in the habit of answering every phone call when it comes in.

3. Encourage family and friends to interrupt your work any time for any reason. An office without a door works best for this; however, you can accomplish the same goal by consistently accepting interruptions, door notwithstanding.

Jokes aside, no one I know has ever announced to their client roster that dropping by the house at 11 PM with a shoebox of receipts is perfectly acceptable. In reality, the sacred boundary of your home office is more likely to erode in small patches. Driven by a sincere desire to help the clients and to provide the best customer service possible, you might make an exception here and there. Trouble is, the other party frequently walks away thinking that the exception is the normal way of doing business with you.

Many professionals working from home have become very adept at appearing to be patient while hating every minute of it. While no one starts their home office adventure by declaring it a free-for-all zone, few take the formal step of thinking through the things they are willing to tolerate—or not—while working. I have found the list below to be a helpful start, whether you are considering setting up a home work space, working in one, or even working in a conventional office arrangement.

1. What are the hours when you are available and open for business?
Choose the hours when you are most productive and able to focus on work. Setting up a phone call with a client at 7 AM or 8 PM may seem like a good idea in a pinch—until it sets an availability precedent that can be difficult to reverse.  Outrageous requests are easy to keep at bay; it is the requests on the fringe of reasonable that erode the boundary.

2. What is your policy on weekends or after-hour availability?
Will you make yourself available, cheerfully and without a grudge, to clients on weekends or after hours? Will it be a one-time arrangement or an ongoing one? How will your clients know the difference?

3. How will you deal with the inevitable interruptions?
Whether it is your child cruising in with the latest drawing, your pet barking while you are on a conference call, a friend stopping by to invite you out for lunch, or a client dropping by unannounced, it helps to have a plan. You are more likely to handle the interruption firmly, gently and with grace if you are prepared.

4. What exemplifies an emergency that requires your immediate and personal attention during your work hours?
Certain situations require an immediate and personal response: an injury to your child, a gas leak, a fire alarm. Be clear on what warrants an interruption, and help those around you get the same clarity.

5. What is your approach to office organization and order?
If you expect clients to visit your home office, how will you keep it professional and presentable? 

 Who is allowed to clean your office?

I encourage you to think through those questions, and come up with your own. The answers will form the basis for your rule book. No matter how good your rule book is, the only rules that matter are the ones that are communicated and enforced. Make sure that your clients understand your general policies. Putting them in a client agreement, or creating a client handbook, is a great start. While creating a written contract with your friends and loved ones may not be practical, be sure that everyone is clear on the rules. Above all else, be prepared to defend your boundary from all trespassers—gently, firmly, and consistently.

Setting boundaries can be a scary proposition. It can feel as though you are putting up walls, digging a moat, and setting up guns along the perimeter. However, it is possible to establish home office boundaries gracefully; as with any skill, this one is mastered with patient practice. It helps to remember that boundaries are not selfish. They can help you create a space to deliver a valuable service, grow your practice, and support yourself and your loved ones.

Circular 230 Disclosure

Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication

IRS Verification Processes Lead to Potentially Fraudulent Tax Refunds

The processes used by the Internal Revenue Service to verify taxpayers’ income and withholding status are inadvertently resulting in the issuance of potentially fraudulent tax refunds, according to a new report.

The report, from the Treasury Inspector General for Tax Administration, noted that a common characteristic of fraudulent tax returns is that the income and withholding reported on the tax return are false. The Electronic Fraud Detection System, or EFDS, is the IRS’s main tool for identifying potentially fraudulent tax returns at the time they are processed. As of April 3, 2013, the IRS reported that it prevented the issuance this year of nearly $1.2 billion in fraudulent tax refunds through its income and withholding verification processes. Yet those same processes are nevertheless leading to the issuance of many potentially fraudulent tax refunds.

TIGTA had earlier reported and testified before Congress that access to current-year third-party income and withholding information at the same time that tax returns are processed is the single most important tool needed by the IRS to identify and prevent tax refund fraud. However, most current-year third party information is not available until well after tax-filing season begins and tax returns are processed, TIGTA pointed out.

In July 2012, TIGTA reported on an analysis of tax year 2010 tax returns in which it identified nearly 1.5 million tax returns that were not detected by the IRS as potentially fraudulent, even though they had the same characteristics as the fraudulent tax returns that the IRS had confirmed as instances of identity theft. Analysis of the 1.5 million undetected tax returns found that only 120,197 (or about 8 percent) received a fraud score high enough to be sent for verification under the IRS’s then-existing processes.

For its latest report, TIGTA reviewed a random sample of 272 of the 120,197 tax returns and found that the IRS’s income and withholding verification process is not always effective in stopping the issuance of fraudulent tax refunds. In the report, TIGTA recommended that the IRS ensure that it take action to prevent the issuance of potentially fraudulent refunds when tax returns are not screened and verified on a timely basis and ensure that the actions it takes in such cases are sufficiently documented. In addition, TIGTA suggested that the IRS should change its procedures to ensure that when tax returns are identified as potentially fraudulent and are assigned to another IRS function for further scrutiny, the tax refunds should be held until the tax returns are screened and verified.

In response to the report, IRS officials agreed with TIGTA’s recommendations and said they have taken action to extend tax account freezes to prevent the release of potentially fraudulent tax refunds. The IRS also plans to re-emphasize the documentation requirements of case actions and revise its instructions for IRS tax examiners to require positive verification that an issue triggering an error code or referral has been addressed.

“The report accurately describes the challenges the IRS faces in processing returns prior to the availability of third-party data,” wrote Peggy Bogadi, commissioner of the IRS’s Wage and Investment Division, in response to the report. “The report is based on tax year 2010 returns that were received and processed during calendar year 2011.  In the two years since those returns were received and processed, the IRS has identified and changed processes where controls needed to be improved and new approaches taken to more effectively address the threats posed by unscrupulous individuals filing fraudulent claims for refund.”

She pointed out that in the first five months of 2013, the IRS has stopped over 1 million fraudulent tax refunds valued at more than $6 billion.

Circular 230 Disclosure

Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication

IRS Releases New Paid Preparer’s Child Tax Credit Checklist, Form 8967

The Internal Revenue Service has released a new due diligence checklist to assist professional tax preparers in 2014.  The three-page Form 8967 is part of the IRS initiative to provide checklists to help improve the accuracy of returns.  It is optional for 2013. 

                    

 The new form asks 21 questions about each child claimed on a tax return.  There are questions about residency, relationship to taxpayer, support, citizenship, adoption, id numbers, physical presence, and other criteria to establish eligibility for the Child Tax Credit.  There are also nine references to other IRS Publications, pointing the preparer to the detailed guidance in order to answer each question correctly.  No stone is left unturned on this beast of a form. 

Since a portion of the Child Tax Credit is refundable, it’s a common area on the tax return for truth-stretching (i.e. fraud).  Form 8967 provides a means for the preparer to document dependent status and ensure, to the best of his or her knowledge, an accurate credit claim.  It could definitely prove to be valuable in the event of an IRS audit – and woe be to preparers who have difficulties with returns and do not have proper documentation on file. 

The introduction of more “due diligence” questions is not a surprise.  The IRS has been aggressive in its release of due diligence materials (see our Taxing Subjects post last year at http://blog.drakesoftware.com/2012/12/extreme-makeover-tax-forms-edition.html).  Recent due diligence documentation has included the expansion of the EIC checklist, Form 8867, to four pages (there are stiff penalties for not filing this form when required); the addition last year of a page 2 to Form 8863, which included more fact-checking questions to validate claims for education credits; and the addition of more questions on page 1 of Form  8812 – Child Tax Credit. 

Will the new Form 8967 help improve return accuracy?  Will preparers use their best judgment and complete the form only for taxpayers who appear questionable?  Or, will they complete the form for all taxpayers (with dependents) and eliminate the risk of being caught in an audit with partial documentation. Or, will they simply ignore them altogether in the hopes that they will lose less time in the preparation of each return and risk the consequences if they are audited.  Only time – and the amount of regulatory documentation required – will tell.

Circular 230 Disclosure

Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication

2014 Tax Season to Start Later Following Government Closure; IRS Sees Heavy Demand As Operations Resume

The Internal Revenue Service today announced a delay of approximately one to two weeks to the start of the 2014 filing season to allow adequate time to program and test tax processing systems following the 16-day federal government closure. 
 
The IRS is exploring options to shorten the expected delay and will announce a final decision on the start of the 2014 filing season in December, Acting IRS Commissioner Danny Werfel said. The original start date of the 2014 filing season was Jan. 21, and with a one- to two-week delay, the IRS would start accepting and processing 2013 individual tax returns no earlier than Jan. 28 and no later than Feb. 4. 

The government closure came during the peak period for preparing IRS systems for the 2014 filing season. Programming, testing and deployment of more than 50 IRS systems is needed to handle processing of nearly 150 million tax returns. Updating these core systems is a complex, year-round process with the majority of the work beginning in the fall of each year. 

About 90 percent of IRS operations were closed during the shutdown, with some major workstreams closed entirely during this period, putting the IRS nearly three weeks behind its tight timetable for being ready to start the 2014 filing season. There are additional training, programming and testing demands on IRS systems this year in order to provide additional refund fraud and identity theft detection and prevention.

“Readying our systems to handle the tax season is an intricate, detailed process, and we must take the time to get it right,” Werfel said. “The adjustment to the start of the filing season provides us the necessary time to program, test and validate our systems so that we can provide a smooth filing and refund process for the nation’s taxpayers. We want the public and tax professionals to know about the delay well in advance so they can prepare for a later start of the filing season.”

The IRS will not process paper tax returns before the start date, which will be announced in December. There is no advantage to filing on paper before the opening date, and taxpayers will receive their tax refunds much faster by using e-file with direct deposit. The April 15 tax deadline is set by statute and will remain in place. However, the IRS reminds taxpayers that anyone can request an automatic six-month extension to file their tax return. The request is easily done with Form 4868, which can be filed electronically or on paper.

IRS processes, applications and databases must be updated annually to reflect tax law updates, business process changes, and programming updates in time for the start of the filing season. 
The IRS continues resuming and assessing operations following the 16-day closure. The IRS is seeing heavy demand on its toll-free telephone lines, walk-in sites and other services from taxpayers and tax practitioners.

During the closure, the IRS received 400,000 pieces of correspondence, on top of the 1 million items already being processed before the shutdown. 

The IRS encourages taxpayers to wait to call or visit if their issue is not urgent, and to continue to use automated applications on IRS.gov whenever possible.

“In the days ahead, we will continue assessing the impact of the shutdown on IRS operations, and we will do everything we can to work through the backlog and pent-up demand,” Werfel said. “We greatly appreciate the patience of taxpayers and the tax professional community during this period.”

Circular 230 Disclosure

Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication

IRS Begins PTIN Renewal Season for 2014

The Preparer Tax Identification Number (PTIN) system is now ready to accept applications, new and renewal, for 2014.

Over the next two months, roughly 690,000 federal tax return preparers must go online and renew their PTIN – all current PTINs will expire on December 31. An IRS-issued PTIN must be used as the identifying number on tax returns by anyone who, for compensation, prepares or helps prepare any federal return or claim for refund.

The renewal fee is $63, and the process can be easily completed online at www.irs.gov. If you can’t remember your user ID and password, the website can help you recover or reset your credentials. Those registering for the first time can also complete the process online. The first time application fee is $64.25.


The IRS is encouraging preparers to renew their PTIN as soon as possible to avoid the last-minute rush. All current PTIN holders will receive a “reminder” email from the IRS in the near future. The online process is much quicker than the paper process – Form W-12, IRS Paid Preparer Tax Identification Number Application and Renewal, is available for paper applications and renewals, but takes four to six weeks to process. In addition, the IRS has made a number of enhancements to improve the online user experience:

- A fully functional “Manage My Account” tool allows preparers to edit their account information online at any time. Prior to this, a phone call to the IRS helpdesk was required for changes made outside of the renewal period.

- Preparers can now view their completed continuing education (CE) programs reported by IRS-approved providers beginning with 2013 courses. CE Providers report completed CE programs to the IRS based on the preparer’s PTIN number. The IRS reminds preparers that it only displays what providers have reported. If a course is missing, contact the CE provider directly.

- Paid preparers (who are not Enrolled Agents) can now make their PTIN inactive if they plan to take a full year off. When they return, they can reactivate the same number online. This should only be used by preparers who are taking a full year off and don’t plan to prepare returns during any part of the year.

- PTIN holders will now receive more secure email messages directly from TaxPro_PTIN@irs.gov. Be sure the email is actually from this address, and don’t hesitate to report suspicious email by following the directions at Report Phishing at IRS.gov.

Failure to have and use a valid PTIN may result in penalties. In addition, all Enrolled Agents, regardless of whether they prepare returns, must have a PTIN in order to maintain their status. For more information about requirements for federal tax professionals and access to the online PTIN system, go to www.irs.gov/ptin.

Circular 230 Disclosure

Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication

IRS Wastes Billions in Bogus Claims for Earned Income Tax Credit

The Internal Revenue Service paid up to $13.6 billion in bogus claims for the Earned Income Tax Credit last year and as much as $132.6 billion over the past decade, according to an internal audit that already has some members of Congress questioning how the agency will be able to administer Obamacare.
 
 IRS problems with the tax credit aren’t new. In fact, the Treasury inspector general for tax administration said it warned officials about the problems in 2011 — but two years later, the agency still hasn’t solved the situation and remains in violation of one of President Obama’s executive orders.

 Indeed, the IRS has not established annual targets for reducing the payments, which is required by law, nor is the agency complying with requirements that it report to auditors each quarter on any EITC payments totaling more than $5,000.

 “The IRS should be commended for implementing numerous processes to educate Americans and identify and prevent improper EITC payments,” said J. Russell George, Treasury inspector general for tax administration. “Unfortunately, it is still distributing more than $11 billion in improper EITC payments each year, and that is disturbing.”

 Mr. George and his investigators said 21 percent to 25 percent of all EITC payments in 2012 were erroneous, meaning $11.6 billion to $13.6 billion was paid to people who shouldn’t have received the credit, or received the wrong amount.

 The EITC is a refundable tax credit designed to transfer money to the working poor through the tax system. It allows the working poor to pay less in taxes or, if they have no tax liability, to get money.
 Both the IRS and the auditors agreed it is a complex program and checking eligibility is difficult.
 The program is popular with many lawmakers on both sides of the aisle who say it’s an effective anti-poverty tool, rewarding those who work.

 But the large error rate left some lawmakers questioning whether the agency will be able to administer the tens of billions of dollars in health care tax credits that are part of the Affordable Care Act.

 “That the IRS can’t figure out how to rein in the improper Earned Income Tax Credit payments doesn’t bode well for the $1.1 trillion in ObamaCare subsidies,” said Sen. Orrin G. Hatch of Utah, the ranking Republican on the Senate Finance Committee.

 He said if the error rate in Obamacare subsidies is as big as it is in the EITC, that could mean $250 billion would be wasted in health care payments.

 The size of the erroneous payments was staggering to lawmakers. At more than $13 billion a year, the bogus tax claims are more than the entire budget of the Environmental Protection Agency or the Interior or Labor departments.

 “The waste outlined in this report — more than $13 billion a year — equals or exceeds the annual budgets of some federal agencies,” said Sen. Tom Coburn, Oklahoma Republican and Congress‘ chief waste-watcher. “Before we ask taxpayers to send even more of their own money to Washington, we must do more to prevent these egregious examples of waste.”

 The IRS said it does try to crack down on bad EITC payments. Americans who claim the tax credit are already audited at twice the rate of other taxpayers.

 “The IRS protects nearly $4 billion in improper claims each year and is committed to continuing to work to reduce improper claims,” the agency said in a statement.

 The agency said it’s working with the White House budget office to try to come up with other ways to weed out bad payments, and promised to soon comply with reporting requirements.

 And it’s already shown some progress in cutting the problem. In 2010, as much as 29 percent of EITC payments were erroneous, accounting for up to $18.4 billion.
 Analysts said the large error rate stems from the complexity of the program, which leaves taxpayers confused about who is able to claim it.

 Then there are the competing goals Congress and Mr. Obama have set.

 For example, in a 2009 executive order the president told agencies to do more to make sure Americans know they are eligible for tax credits. But he also told agencies to crack down on bogus payments, laying out the reporting goals that the inspector general said the IRS is violating.

Circular 230 Disclosure

Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication

IRS Releases Preliminary Report on ObamaCare Inquiries

The IRS on Saturday reported handling more than 330,000 requests from ObamaCare exchanges to calculate whether Americans are eligible for federal tax credits when purchasing insurance through the program, Fox News reports. 

The release provides some indication on how many people are attempting to buy insurance through the exchanges in their first four weeks of operation and how many are seeking federal financial assistance.

The agency said it is receiving about 80,000 data requests daily. 
The IRS said it “remains on track with implementing its portion of the Affordable Care Act and continues actively supporting the Health Insurance Marketplaces,” amid widespread problems with the online exchanges and resulting backlash. 

The Obama administration has yet to release information on the number of Americans who have bought insurance through the exchange, perhaps the best indicator of public interest and the success of the program, but has vowed to in the coming months. 

The IRS also reported that it has received and responded to more than 1.3 million requests from the marketplaces about household income and the size of families, which the agency called “critical” information in determining applicants’ eligibility for “income-based financial assistance.”

Circular 230 Disclosure

Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication

Happy Birthday! Or not. Income tax turns 100 years old

Happy Birthday to you! Happy Birthday to you! You don't look a day over 99. 

It's doubtful most people will notice, let alone celebrate, Friday's 100th anniversary of the U.S. income tax code. But, yes taxpayers, Oct. 4, 2013, is the centennial.

So, happy birthday income tax?

In 1913, the tax code consisted of 400 pages. By 2012, the tax code was 73,608 pages, and we have gone from a simple tax system to a complex, unfriendly system.

It was the 16th Amendment, adopted in February 1913, that gave Congress the legal right to levy an income tax. On the evening of Oct. 3, President Woodrow Wilson signed the Revenue Act of 1913 that allowed the collection of a federal income tax—starting the next day. 

But having some sort of taxation goes back to the country's beginning. From 1791 to 1802, the government was supported by tax revenue from the sale of such items as liquor, tobacco, sugar, property sold at auction and even through the sale of slaves. 

The high cost of the War of 1812 saw the first sales tax on gold, silverware, jewelry and watches. But by 1817, Congress eliminated all taxes and relied on tariffs from imported goods for revenues. 

It was in 1862, to fund the Civil War, that Congress enacted the first income tax. Anyone making between $300 to $10,000 a year paid a rate of 3 percent. That tax ended soon after the war.

Congress also established the Internal Revenue Service at the same time, which had much the same power and authority then as it does now. 

Jumping to 1894, Congress passed the first peacetime income tax law, but a year later the Supreme Court declared it unconstitutional. The court said that taxes on rents and real estate income had to be divided among the states according to population, which the law did not allow. 

But the court did make a crucial statement in its ruling. It said that Congress had the right to impose a direct income tax—and that led to the passage of the 16th Amendment. 

Taxes in the post-World War II era were very high, at a 70 to 80 percent rate in some cases, and people were more or less willing to pay them.

But our overall prosperity started to decline in the 1960s and '70s, and people wanted to start paying less in taxes. 

The tax system has seen its share of changes over the years. In 1943, the withholding tax on wages was introduced for the first time. In 1981, Congress passed the largest tax cut in American history, some $750 billion in cuts over six years. That was partially offset in 1982 and 1984 when Congress raised taxes to the tune of $265 billion. 

The Tax Reform Act of 1986 is considered the biggest reform measure since 1913. The top tax rate on individual income was lowered from 50 percent to 28 percent, the lowest it had been since 1916.

But along with the lower rate came the elimination of certain loopholes to make up the lost revenue. And the act put in a $120 billion increase in business taxes. 

President George W. Bush signed several tax cuts into law in 2001 for the third-largest tax cut since World War II. President Barack Obama's tax bill for 2013 kept some of the Bush tax cuts for lower incomes but raised levels for higher incomes, which had been reduced under Bush. 

Among other moves, Obama restored the full amount of the payroll tax (6.3 percent) and raised the rates on capital gains and included a 3.8 percent surtax on incomes of $200,000 or more for single people to help fund the Affordable Care Act. The dreaded alternative minimum tax (AMT) received a permanent patch to try to keep thousands from having to pay it. 

Calls for tax reform have led to recent hearings on Capitol Hill. Suggestions include going to a flat tax and eliminating deductions like mortgage interest and charitable giving. 

Taxes are always a hot button issue. Depending on whose study you look at—or your political persuasion—the U.S. is either the most overtaxed nation on the planet, the least taxed (especially for the wealthy), or it's somewhere in the middle, as some have said. 

Wherever it is, taxes are money for government services, like Social Security, Medicare, defense, federal worker payrolls, veterans' benefits, education and health care. 

And the amount needed keeps growing. The Treasury Department will likely collect around $4.9 trillion from income and payroll taxes in 2014. That's a huge jump from the $5.4 billion collected in 1920 and the $43 billion in 1945. 

If Americans do circle their calendars for taxes, it's usually April 15, the yearly filing day, not the 100th birthday of the federal income tax.

Circular 230 Disclosure

Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication