Tax Changes
Most of the changes in taxes this year have to do with expiring provisions, many of which expire at the end of 2012 and create planning opportunities to discuss with my clients next year, but many expire in 2011 and I need to warn my clients that their taxes will be going up in 2012. Fun.
Some planning opportunities:
The refundable adoption credit, which was quite a bonanza to people who adopted kids last year, goes back down to a more sedate level after 2012, so do try to complete adoptions in 2012 if you're on the verge of doing so. You essentially get a credit back for all the costs of adopting, i.e., the Feds are paying your legal bills in full. These were 100% audited, by the way: every single one of them was selected for examination the same way as the $8000 New Home Buyer credit was. My clients submitted copies of their paperwork and the credits were eventually approved, though.
The floor on being able to itemize medical deductions goes up after 2012, so that the first 10% of your AGI won't be deductible rather than the first 7.5% of AGI. People who are over 65 (at time of passage? At 2013? I'm not sure) get a phase-in for three more years and then it goes up in (after?) 2017. This is a planning issue for people who are thinking about buying into an assisted living center. The initial downpayment can be quite large and you'll want to itemize medical that year: best to do it before the floor goes up to 10% if you're trying to decide when.
The legislation that "fixed" the marriage penalty (a little bit of the worst parts) by doubling the standard exemption for married people to twice that of single people is expiring in 2012, so if you are smart you'll plan to divorce before the end of 2013. (I'm considering having B. move to Maine and I stay here and we file HoH and MFS as an intermediate step, but I still sincerely consider the advantages of dissolving our marriage in terms of cold hard cash saved each and every month for the rest of our lives. Hmmmm.)
Getting Earned Income Credit will be harder than ever this year: expect more scrutiny at the time the return is being prepared. I plan on interviewing clients and taking notes and having them sign the interview form... and charging for the pleasure. If you are a poor person who is receiving Earned Income Credit please do not be offended. The IRS is making us by levying a $100 penalty on each return they determine does not have sufficient interview notes on, and can fine us up to $100,000 if we're systematically doing it wrong and disbar us from engaging in our profession. Yes, poor people will feel persecuted. Please discuss it with your congressman.
Other things that expire in 2011: the expanded earned income credit (it covers people with AGIs of up to the median income now, plus tops out a few thousand higher at around $6K for people making about $15K) is gone for 2012. So in the Spring of 2012 when I'm subjecting poor people to scrutiny about who they're sleeping with and who shares DNA with their various children and who bought the groceries last week and which parent had shared custody for ONE DAY MORE than the other, I also have to tell them that they should not expect this "work incentive" to continue to be this generous in in 2012, but I won't be able to tell them what they CAN expect for an item that constitutes 1/3 of their income. So sorry. Discuss it with Congress, please.
Speaking of things to discuss with your congressman, the AMT "patch" they put in for 2010 in December of 2010 was for two years, so it goes through 2011. But there is not patch in for 2012, and 2012 starts in six weeks. We're being set up for another year of not having the faintest clue what the tax rate will be on current income. Congress apparently does not understand the impact of uncertainty on business decisions.
Also, the $1000 refundable child tax credit expires in 2011. (I think it goes back down to $600 per kid under 17 and isn't refundable.)
I'm pretty sure that the solar credits expire in 2011, but not positive. I know the credit for constructing a new energy-efficient home expires in December.
All those wonderful education credits that I adore: actual government help to give people a step up the ladder by paying for a community college education... the American Opportunity Tax Credit expires at the end of 2011. (So pay your 2012 tuition bill early!)
The deductibility of private mortgage insurance, essentially an extra interest rate banks charged if you were poor, is going away after 2011. (But you can still deduct mortgage interest on up to two homes plus home equity mortgage associated with improving your home(s). The only loophole going away is the one for poor people's mortgages.)
I loved the way we could expense start-up expenses in 2010, but that was a one-year provision, too, so just after I learned it (and recommended it last week to a bunch of new business start-ups at a talk I was giving) the rule is already obsolete. Way to give new businesses the ability to plan, Congress!
Also, the Research Tax Credit expires in 2011, so does the $250 above-the-line deduction for all the school teachers, and so does the election to take state sales tax deduction instead of state income taxes (which helped primarily Florida and Texas residents, a gift from the Bush family.)
But the MAIN gift from the Bush family, the 0% rate on trust fund income, expires at the end of 2012.
Self-employed people are getting whiplash from the levying of SE tax. In 2010 we got to FINALLY deduct health insurance expense against our self-employment tax. (All salaried people already got to do that.) But it turns out to have been a one year gift: it's gone in 2011. For an average SE worker paying $8K for their health insurance policy that's a $1200 increase in their taxes in 2011 over what they paid in 2010. Except that in 2011 they reduced the SE tax rate as a special one-year gift to 13.3% instead of 15.3%, so the tax hit from losing the SE health insurance deduction (which is bizarrely unfair) will be only $1100, not $1200. Furthermore, a person making $50K in SE will save roughly $1K in SE tax because of the one year drop, so they may not NOTICE at all. But... in 2012 they will have to pay SE tax on their health insurance AND the rate goes back up, so their quarterlies will be based on assuming they'll be paying $1200 more in taxes on the exact same income. I'm sure we will all enjoy this cozy chat as I tell the self-employed people why they have to pay $300 more each quarterly on the exact same income.
The tax code is littered with chances to expense capital equipment with things like "bonus depreciation" and "enhanced Section 179" and new "qualified property". They throw it out like candy at a parade. I do not recommend that you chase under the wheels of cars to pick up dirty pieces of hard candy to raise your blood sugar levels with, and nor do I recommend that you expense your business capital equipment in years with low rates so that you have no expenses to offset income in years with high rates. General rule of thumb for goodies Congress hands out: they do NOT have your best interest at heart. Unless the code reads something like, "Assets placed in service after Dec. 5, 2011 and before Jan. 31, 2012 that are composed of combined resin products that would be determined to have a 15 year life in Class 3 MACRES property may be expensed in full in the first year in which they are contemplated to be installed and within 60 days of their actual install date." When you read an item like that it means that some rancher bought a fence and wants to deduct it ALL instead of depreciating it but it won't be completely installed before year-end so he called his congressman and got an exemption written in as a rider on some other bill and now it's the law of the land and 10,000 CPAs spend an hour of their life discussing it. This is how tax code is made. If you didn't personally pay for the provision then it is probably not going to be overall to your benefit to use it.
Let's see, some other things that are expiring:
The $400 "economic stimulus credit" that we got in 2009 and 2010 is gone for 2011. Hardly anyone ever noticed that $400 because they messed with withholding tables starting in 2009 so you'd have $8 less withheld each week all it. (It was replaced with the reduction in social security tax for 2011, but you probably never noticed it when you got the extra amount because they readjusted the tax withholding tables at the same time... you're just going to notice when it goes back up and feels like a 2% cut in pay starting in six weeks.
General Business Credit carrybacks that were offered to entice people to invest in business because the credits could be more useful... that provision expired in 2010.
Small businesses that become C Corps before year end may qualify for the 0% rate on capital gains of their stock when they sell their company someday if it was formed before 12/31/11 as a eligible small business stock. Which means if you are an LLC or an S Corp and think you're going to want to sell your business someday at a gain you might consider this. Except I don't know a single small business selling stock, they're all selling ASSETS. No one wants to buy the stock because that means you buy the company's liabilities, and the only time that ever happens is if you have massive carryover losses that they want to obtain, in which case you probably don't have massive capital gains. But, whatever, it's got small business people calling their lawyers.
Same with C corps turning S, there's a thing about reducing the period of built-in capital gains from 7 years to 5 years if you convert this year.
Between these two provisions the only sane thing to do is to call your business attorney and pay him or her to evaluate your best option for entity formation. Personally, I'm pretty impressed with S Corps for people who have payroll, and sole proprietorships for people who don't actually need an entity. But I'm not an attorney, so what do I know. LLCs are all the popular rage. Sort of like Quickbooks. If everyone is doing it then it must be the right answer, right? (Uh... have you MET Congress?)
Oh, and of course, the whole estate tax thing is completely up in the year. This year there's a $5M gift tax exemption and it's supposed to go back down to $1M next year and there's some bizarre hope that if you gift $5M into a trust this year you can keep this off your estate taxes someday when/if the exemption goes back down, as if Congress won't consider doing a clawback to include the assets of rich people with good lawyers when they change the tax law for people who are not dead yet. I have to say that it's bizarre and stupid to believe it, yet utterly plausible that Congress would give a super sweet loophole like that to the rich, so I think you should go ahead and do it: call your lawyer and set up a trust and gift your second through fifth million dollars of assets into a trust, preferably for the benefit of your grandchildren. Estate attorneys are busier than one-armed paper hangers right now. They call all this dithering "The Estate Attorney Full Employment Act of 2010".
A bunch of stuff expired in 2010, including the energy credits for insulating your house where you could get up to 30% of $5000 in improvements for a total credit of $1500. It's now down to 10% of the first $5000 (with a bunch of fine print and asterisks), and you only get $500 CUMULATIVE for all the years since 2005. (Which also means I now have to check five back years of returns before I can give anyone this credit. Lovely, a compliance cost that is likely to be more than the credit, just what taxpayers were yearning for.)
I'm going to have to make sure I discuss with people whether they have any foreign bank accounts or investments that were at any time cumulatively valued of $10,000 during the year, because the Treasury Department has come up with a way to seize your assets if you don't follow their rules precisely. Unfortunately, no one is exactly sure how to precisely follow their rules, so this will be a fun conversation.
Also, everyone should brace themselves for a 2% cut in pay at work on January 1st. The one-year provision reducing social security withholdings from your paycheck from 6.2% down to 4.2% are going to expire next month.
Another fun discussion will be about how there is no patch for AMT in 2012 and millions and millions of taxpayers - including me - won't have the vaguest idea of what their tax bill will be for 2012. I'll be explaining this to them in the first quarter of 2012 right before the quarterly is due for an unknown amount that we are pretty much going to have to presume will be far higher.
By this point I hope you have some sympathy for how it could be that people find themselves deeply into tax debt. I have a few clients who are in "IRS hell", i.e., fallen into the collections department. There is potentially some good news for them. Anyone with a federal lien on their mortgaged property should read up on the new "Fresh Start" provisions that the IRS has just announced. They will have to then call the agent who has their collections matter in their inventory and educate the collections agent on the IRS provisions to remove liens so you can refinance a property. (Google "Fresh Start IRS lien" and then send the blog articles to the IRS agents because they don't know bout them.) Also, the IRS is changing the rules about recording liens from when you owe $5K to when you owe $10K. This is nice at some levels, but dangerous at others. For example, the people who you contract with and owe you money may have a hidden IRS lien that is superior to your claim for payment that you don't know about and can't find out about. But if you have an IRS lien right now on you for between $5K and $10K you may be able to get it hidden from sight. (The lien still exists, it's just that people who you're trying to borrow money from won't see it.)
Any other good news? We've got expiring deductions and loopholes everywhere, and uncertainty with regard to provisions expected to be extended... but maybe not... that means we really have no idea how much the government will be demanding of our income next year. We've got a Congress who cannot execute ANY good laws whatsoever, but still appear capable of making bad laws... and of course, their main hallmark characteristic is failure to act when necessary. The only way I can imagine to salvage this situation is if Congress made a pledge to do nothing whatsoever. Then we'd have higher taxes, but at least know what they WERE before we went off to work that day. Sadly, this is a fantasy. The reality is that we will have no idea what the tax rate will be on our income until months after we do the work.
Good things... good things... hmmmm.
Well, I think we can count it as good news that we've had so many Federal disaster zones. There is a provision that lets you amend the prior year return to show current year casualty loss to accelerate your refunds if you were in an approved Federal disaster zone, of which there were many many in my area after the hurricane and tornado and freak winter storm... except that paper amends take 8 weeks to process and three weeks to cut a paper check, and the e-file season opens in 8 weeks and takes 1 week to cut a direct deposit check. So never mind that at this point.
They removed the imposition on 1099-MISCs for everyone including contractors at rental homes, but they've created a new nightmare on Schedule D for the new 1099-Bs to flow through to, and those will be rife with error. Oh, and there's a new 1099-K for merchants that doesn't include merchant fees that are withdrawn from direct sales, so those will all need reconciliations and most people were recording their income net of fees so we are going to have to scramble to make sure we don't show too much income on those merchant returns.
With regard to state taxes, all the attention is on sales and use tax and the internet. Perhaps I'll tell you about that someday. Perhaps not.
I'm supposed to add a "no reliance" paragraph on the end of this: the IRS ethics office requires that I explain to you that nothing I said is as authoritative as the IRS is, and that you may not rely on anything I said because they will superimpose their opinion on mine and they will be the correct ones, not me. So, yeah. Don't rely on anything I said.
Some planning opportunities:
The refundable adoption credit, which was quite a bonanza to people who adopted kids last year, goes back down to a more sedate level after 2012, so do try to complete adoptions in 2012 if you're on the verge of doing so. You essentially get a credit back for all the costs of adopting, i.e., the Feds are paying your legal bills in full. These were 100% audited, by the way: every single one of them was selected for examination the same way as the $8000 New Home Buyer credit was. My clients submitted copies of their paperwork and the credits were eventually approved, though.
The floor on being able to itemize medical deductions goes up after 2012, so that the first 10% of your AGI won't be deductible rather than the first 7.5% of AGI. People who are over 65 (at time of passage? At 2013? I'm not sure) get a phase-in for three more years and then it goes up in (after?) 2017. This is a planning issue for people who are thinking about buying into an assisted living center. The initial downpayment can be quite large and you'll want to itemize medical that year: best to do it before the floor goes up to 10% if you're trying to decide when.
The legislation that "fixed" the marriage penalty (a little bit of the worst parts) by doubling the standard exemption for married people to twice that of single people is expiring in 2012, so if you are smart you'll plan to divorce before the end of 2013. (I'm considering having B. move to Maine and I stay here and we file HoH and MFS as an intermediate step, but I still sincerely consider the advantages of dissolving our marriage in terms of cold hard cash saved each and every month for the rest of our lives. Hmmmm.)
Getting Earned Income Credit will be harder than ever this year: expect more scrutiny at the time the return is being prepared. I plan on interviewing clients and taking notes and having them sign the interview form... and charging for the pleasure. If you are a poor person who is receiving Earned Income Credit please do not be offended. The IRS is making us by levying a $100 penalty on each return they determine does not have sufficient interview notes on, and can fine us up to $100,000 if we're systematically doing it wrong and disbar us from engaging in our profession. Yes, poor people will feel persecuted. Please discuss it with your congressman.
Other things that expire in 2011: the expanded earned income credit (it covers people with AGIs of up to the median income now, plus tops out a few thousand higher at around $6K for people making about $15K) is gone for 2012. So in the Spring of 2012 when I'm subjecting poor people to scrutiny about who they're sleeping with and who shares DNA with their various children and who bought the groceries last week and which parent had shared custody for ONE DAY MORE than the other, I also have to tell them that they should not expect this "work incentive" to continue to be this generous in in 2012, but I won't be able to tell them what they CAN expect for an item that constitutes 1/3 of their income. So sorry. Discuss it with Congress, please.
Speaking of things to discuss with your congressman, the AMT "patch" they put in for 2010 in December of 2010 was for two years, so it goes through 2011. But there is not patch in for 2012, and 2012 starts in six weeks. We're being set up for another year of not having the faintest clue what the tax rate will be on current income. Congress apparently does not understand the impact of uncertainty on business decisions.
Also, the $1000 refundable child tax credit expires in 2011. (I think it goes back down to $600 per kid under 17 and isn't refundable.)
I'm pretty sure that the solar credits expire in 2011, but not positive. I know the credit for constructing a new energy-efficient home expires in December.
All those wonderful education credits that I adore: actual government help to give people a step up the ladder by paying for a community college education... the American Opportunity Tax Credit expires at the end of 2011. (So pay your 2012 tuition bill early!)
The deductibility of private mortgage insurance, essentially an extra interest rate banks charged if you were poor, is going away after 2011. (But you can still deduct mortgage interest on up to two homes plus home equity mortgage associated with improving your home(s). The only loophole going away is the one for poor people's mortgages.)
I loved the way we could expense start-up expenses in 2010, but that was a one-year provision, too, so just after I learned it (and recommended it last week to a bunch of new business start-ups at a talk I was giving) the rule is already obsolete. Way to give new businesses the ability to plan, Congress!
Also, the Research Tax Credit expires in 2011, so does the $250 above-the-line deduction for all the school teachers, and so does the election to take state sales tax deduction instead of state income taxes (which helped primarily Florida and Texas residents, a gift from the Bush family.)
But the MAIN gift from the Bush family, the 0% rate on trust fund income, expires at the end of 2012.
Self-employed people are getting whiplash from the levying of SE tax. In 2010 we got to FINALLY deduct health insurance expense against our self-employment tax. (All salaried people already got to do that.) But it turns out to have been a one year gift: it's gone in 2011. For an average SE worker paying $8K for their health insurance policy that's a $1200 increase in their taxes in 2011 over what they paid in 2010. Except that in 2011 they reduced the SE tax rate as a special one-year gift to 13.3% instead of 15.3%, so the tax hit from losing the SE health insurance deduction (which is bizarrely unfair) will be only $1100, not $1200. Furthermore, a person making $50K in SE will save roughly $1K in SE tax because of the one year drop, so they may not NOTICE at all. But... in 2012 they will have to pay SE tax on their health insurance AND the rate goes back up, so their quarterlies will be based on assuming they'll be paying $1200 more in taxes on the exact same income. I'm sure we will all enjoy this cozy chat as I tell the self-employed people why they have to pay $300 more each quarterly on the exact same income.
The tax code is littered with chances to expense capital equipment with things like "bonus depreciation" and "enhanced Section 179" and new "qualified property". They throw it out like candy at a parade. I do not recommend that you chase under the wheels of cars to pick up dirty pieces of hard candy to raise your blood sugar levels with, and nor do I recommend that you expense your business capital equipment in years with low rates so that you have no expenses to offset income in years with high rates. General rule of thumb for goodies Congress hands out: they do NOT have your best interest at heart. Unless the code reads something like, "Assets placed in service after Dec. 5, 2011 and before Jan. 31, 2012 that are composed of combined resin products that would be determined to have a 15 year life in Class 3 MACRES property may be expensed in full in the first year in which they are contemplated to be installed and within 60 days of their actual install date." When you read an item like that it means that some rancher bought a fence and wants to deduct it ALL instead of depreciating it but it won't be completely installed before year-end so he called his congressman and got an exemption written in as a rider on some other bill and now it's the law of the land and 10,000 CPAs spend an hour of their life discussing it. This is how tax code is made. If you didn't personally pay for the provision then it is probably not going to be overall to your benefit to use it.
Let's see, some other things that are expiring:
The $400 "economic stimulus credit" that we got in 2009 and 2010 is gone for 2011. Hardly anyone ever noticed that $400 because they messed with withholding tables starting in 2009 so you'd have $8 less withheld each week all it. (It was replaced with the reduction in social security tax for 2011, but you probably never noticed it when you got the extra amount because they readjusted the tax withholding tables at the same time... you're just going to notice when it goes back up and feels like a 2% cut in pay starting in six weeks.
General Business Credit carrybacks that were offered to entice people to invest in business because the credits could be more useful... that provision expired in 2010.
Small businesses that become C Corps before year end may qualify for the 0% rate on capital gains of their stock when they sell their company someday if it was formed before 12/31/11 as a eligible small business stock. Which means if you are an LLC or an S Corp and think you're going to want to sell your business someday at a gain you might consider this. Except I don't know a single small business selling stock, they're all selling ASSETS. No one wants to buy the stock because that means you buy the company's liabilities, and the only time that ever happens is if you have massive carryover losses that they want to obtain, in which case you probably don't have massive capital gains. But, whatever, it's got small business people calling their lawyers.
Same with C corps turning S, there's a thing about reducing the period of built-in capital gains from 7 years to 5 years if you convert this year.
Between these two provisions the only sane thing to do is to call your business attorney and pay him or her to evaluate your best option for entity formation. Personally, I'm pretty impressed with S Corps for people who have payroll, and sole proprietorships for people who don't actually need an entity. But I'm not an attorney, so what do I know. LLCs are all the popular rage. Sort of like Quickbooks. If everyone is doing it then it must be the right answer, right? (Uh... have you MET Congress?)
Oh, and of course, the whole estate tax thing is completely up in the year. This year there's a $5M gift tax exemption and it's supposed to go back down to $1M next year and there's some bizarre hope that if you gift $5M into a trust this year you can keep this off your estate taxes someday when/if the exemption goes back down, as if Congress won't consider doing a clawback to include the assets of rich people with good lawyers when they change the tax law for people who are not dead yet. I have to say that it's bizarre and stupid to believe it, yet utterly plausible that Congress would give a super sweet loophole like that to the rich, so I think you should go ahead and do it: call your lawyer and set up a trust and gift your second through fifth million dollars of assets into a trust, preferably for the benefit of your grandchildren. Estate attorneys are busier than one-armed paper hangers right now. They call all this dithering "The Estate Attorney Full Employment Act of 2010".
A bunch of stuff expired in 2010, including the energy credits for insulating your house where you could get up to 30% of $5000 in improvements for a total credit of $1500. It's now down to 10% of the first $5000 (with a bunch of fine print and asterisks), and you only get $500 CUMULATIVE for all the years since 2005. (Which also means I now have to check five back years of returns before I can give anyone this credit. Lovely, a compliance cost that is likely to be more than the credit, just what taxpayers were yearning for.)
I'm going to have to make sure I discuss with people whether they have any foreign bank accounts or investments that were at any time cumulatively valued of $10,000 during the year, because the Treasury Department has come up with a way to seize your assets if you don't follow their rules precisely. Unfortunately, no one is exactly sure how to precisely follow their rules, so this will be a fun conversation.
Also, everyone should brace themselves for a 2% cut in pay at work on January 1st. The one-year provision reducing social security withholdings from your paycheck from 6.2% down to 4.2% are going to expire next month.
Another fun discussion will be about how there is no patch for AMT in 2012 and millions and millions of taxpayers - including me - won't have the vaguest idea of what their tax bill will be for 2012. I'll be explaining this to them in the first quarter of 2012 right before the quarterly is due for an unknown amount that we are pretty much going to have to presume will be far higher.
By this point I hope you have some sympathy for how it could be that people find themselves deeply into tax debt. I have a few clients who are in "IRS hell", i.e., fallen into the collections department. There is potentially some good news for them. Anyone with a federal lien on their mortgaged property should read up on the new "Fresh Start" provisions that the IRS has just announced. They will have to then call the agent who has their collections matter in their inventory and educate the collections agent on the IRS provisions to remove liens so you can refinance a property. (Google "Fresh Start IRS lien" and then send the blog articles to the IRS agents because they don't know bout them.) Also, the IRS is changing the rules about recording liens from when you owe $5K to when you owe $10K. This is nice at some levels, but dangerous at others. For example, the people who you contract with and owe you money may have a hidden IRS lien that is superior to your claim for payment that you don't know about and can't find out about. But if you have an IRS lien right now on you for between $5K and $10K you may be able to get it hidden from sight. (The lien still exists, it's just that people who you're trying to borrow money from won't see it.)
Any other good news? We've got expiring deductions and loopholes everywhere, and uncertainty with regard to provisions expected to be extended... but maybe not... that means we really have no idea how much the government will be demanding of our income next year. We've got a Congress who cannot execute ANY good laws whatsoever, but still appear capable of making bad laws... and of course, their main hallmark characteristic is failure to act when necessary. The only way I can imagine to salvage this situation is if Congress made a pledge to do nothing whatsoever. Then we'd have higher taxes, but at least know what they WERE before we went off to work that day. Sadly, this is a fantasy. The reality is that we will have no idea what the tax rate will be on our income until months after we do the work.
Good things... good things... hmmmm.
Well, I think we can count it as good news that we've had so many Federal disaster zones. There is a provision that lets you amend the prior year return to show current year casualty loss to accelerate your refunds if you were in an approved Federal disaster zone, of which there were many many in my area after the hurricane and tornado and freak winter storm... except that paper amends take 8 weeks to process and three weeks to cut a paper check, and the e-file season opens in 8 weeks and takes 1 week to cut a direct deposit check. So never mind that at this point.
They removed the imposition on 1099-MISCs for everyone including contractors at rental homes, but they've created a new nightmare on Schedule D for the new 1099-Bs to flow through to, and those will be rife with error. Oh, and there's a new 1099-K for merchants that doesn't include merchant fees that are withdrawn from direct sales, so those will all need reconciliations and most people were recording their income net of fees so we are going to have to scramble to make sure we don't show too much income on those merchant returns.
With regard to state taxes, all the attention is on sales and use tax and the internet. Perhaps I'll tell you about that someday. Perhaps not.
I'm supposed to add a "no reliance" paragraph on the end of this: the IRS ethics office requires that I explain to you that nothing I said is as authoritative as the IRS is, and that you may not rely on anything I said because they will superimpose their opinion on mine and they will be the correct ones, not me. So, yeah. Don't rely on anything I said.