Irony

I remember a gift tax case I worked back in '05 or '06. The taxpayer had been instrumental in the development of a local corporation that became quite large. When his business was taken over by a publicaly traded company, he got a LOT of stock in the big company. A LOT OF STOCK. For the sake of numbers, we'll say his holdings (in one, publically-traded company) had a street value of $10 million.

He couldn't sell the stock and realize $10 million. If he had attempted to sell off even half of it, the value on the daily market would likely have plunged.

He was, in effect handcuffed by gold. He owned the stock, he received VERY nice dividends, but he couldn't sell enough stock in a brief time to give himself full liquidity.

He was not a young man. The stock would be valued at it's trading price on the day he died, and his estate would be taxed on that $10 million dollars.

Not a financially comfortable picture.

The gentleman was no fool. He met with his attorneys, and they developed a plan to minimize the estate tax effect of his stock ownership.

First, he transferred the stock from himself to a corporation. This corporation held two classes of stock - common and prefered. Each class of stock was divided into two characteristics - voting and non-voting.

There were further restrictions on the ability of any share holder to sell their stock to anyone outside of the corporation.

I was charged with auditing the gift tax returns for the gifts of stock in the corporation that he made to his children and grandchildren.

Now, when you take stock that trades on the public market for %10 million dollars and pays a regular dividend, and you manage, through expensive planning to put that stock into a corporation where it does not necesarily pay a dividend, where it cannot be sold outside of the corporation, and may or may not have any voting rights, the stock becomes worth less than $10 million. A minority interest in a non-liquid asset may be worth less than 50% of the fair market value of the asset on an unrestricted basis.

Yes, this gentleman had planned, and planned well to avoid a large portion of the estate tax that might otherwise be due upon his demise.

His plan was sufficiently sophisticated that after spending a considerable amount of time attempting to find it's weak points, I decided NOT to propose any adjustments to the gift tax returns.

The gentleman had probably payed between $150,000 and $500,000 to set up the plan. He probably payed another $10,000 for the gift tax returns that I was examining. In addition, there was another fee for the appraisals of the various classes of stock that were gifted.

Now recognize that the estate tax on $10 million would have been approximately $4.5 million. Of course, he owned other assets beyond the stock. H may have paid as much as one million dollars to avoid a portion of the $4.5 million.

I had the first year he had set up the complicated structure. He probably made more gifts of stock in the subsequent years.

Of course, the corporation he set u had to file annual returns also.

Irony?

He died in 2010. I saw his obituary in the newspaper.

In 2010, there is/was NO estate tax. His heirs could have recieved the stock unrestricted and tax free. Instead, they receive the stock subject to the corporate structure he established in order to avoid estate taxes. They will likely pay the attorneys another quarter of a million dollars to un-do the structrue he set up.

All that very, very expensive work gave no benefit to his heirs. In fact, it has cost them more to un-do it. They received the stock as a gift, which means that the value in their hands is NOT the value as of his death, but a lesser amount.

Irony. He planned well, and Congress disposed of matters in a different way.

RIP

Cookies, Anyone?

As a person who loves to cook, I naturally make cookies. This time of year, I make a LOT of cookies.

You see, there is only me and George. If I bake one batch of cookies, the two of us eat the entire batch. Bad result. Therefore, I bake a LOT of cookies. Some years, I make a dozen different types. Result?

1. I am so sick of cookies that I have no desire to eat any.

2. I have goodies to give to all of my friends. (One year, everyone in my group got a bag of assorted cookies. They all loved me!)

And what is Christmas without cookies? This is part of my way of celebrating the season.

I try at least one new recipe every year.

This year, the first new one was a Martha Stewart honey-walnut confection. I should have smelled a rat when she used a food processor to reduce the toasted walnuts to meal. Everyone knows that you put the toasted nuts in a plastic bag and use the rolling pin to reduce them to meal. Anyway, this one is a sort of shortbread. I may keep it for the honey proportions and tweak it a bit -- add lemon zest and cinnamon and convert it into a sort of baklava shortbread.

I'm golfing tomorrow. The ladies playing with me will get some of my "tried and true" cookies as a treat. George fed some to the guys he golfed with today. They LOVED them. Of course, at this rate, I'll have to bake at least 3 more batches before the weekend.

Sometimes life is tough. Sometimes it's just sweet. That's the way the cookie crumbles.

Addiction exposed

My computer had to go in for some work. I took it in on Sunday, the 21st, and did not get it back until Friday the 26th.

What did I DO for those days?

I read, I fretted, I tried to figure out what to do with myself without my adult, electronic -sitter.

How did I ever become so dependent on a machine?

I was lucky. I did not experience any symptoms of substance withdrawal. Perhaps that was because I knew that my drug of choice would soon be returned to me.

Or perhaps the fretting, the pacing, the wandering through rooms looking for SOMETHING to do WERE symptoms of withdrawal.

So, I must confess, I am a computer addict. Life without the internet is flat. The internet gives depth and texture to me.

YEACH!!!!!!

Plus que ca change, plus que c'est le meme chose

"The more things change, the more they stay the same"

Over dinner tonite, my friend and I were talking about some of the expectations we had regarding our retirements and moving to a new state.

I suddenly had a flash-back to something I had read in either junior high school or my first year of high school. I was reading a publication of the best writing of high school students of some time in the late 1960's.

There was one story that dealt with guys riding in box cars, looking for work, and telling some kid to jump off on a curve near a certain town. The curve was too fast for a person to jump off and not receive serious injury. The "old-timers" were setting a possible death sentence for the rookie.

Another story, which was recalled to my memory immediately, dealt with a young man moving from the south to the north. The man's race was never mentioned. The northern city was never mentioned. The theme was that the same term was addressed to the young man in both cities. He had move north, hoping for a better life, and found that he was still called by the same term.

My friend and I are hetro-sexual, anglo-saxons. We are NOT any type of minority, any type of 'oppressed' group. We both thougt life would be different here. Somehow, we both thought that HERE, there would be more people who thought before they spoke, who valued knowledge over degrees, who would ENCOURAGE independent thought rather than embracing sameness.

Tonight, we laughed over our naivite. No place is any different than any other. Walden II does not exist. People ARE people the world over. In China, in Antartica, we would find people who think they are better than we are (perhaps because they REFUSE to think) Some of them (probably the ones in Antartica) WOULD be better (or at least smarter) than us. Some of them would not be smarter or better, and some of them would be the same, yet different.

I need to embrace a world in which there are people I believe are absolute f**king morons. And I need to accept their right to exist in this world, even if I think they are wasting valuable atoms of oxygen.

Sad Thoughts

Normally, I love flowers. I usually buy them everytime I go to the grocery store. Sometimes I splurge and go to the local florest and buy myself something special.

Today, I did NOT like buying flowers.

I bought them for a friend's funeral.

Marcella, I wish I that THOUGHT and sent you flowers while you were alive.

You were a very special, a very dear friend. You weren't just my friend. Everyone who came into contact with you loved you.

Your smile, your laugh, they could light up an entire room.

You were down-to-earth, practical, sensible and funny. You had such a big heart. Perhaps it wore out early because you kept it so open to everyone.

Perhaps today, on some golf course in heaven, you are playing again with Bernie, Helen and the other ladies of the 9-hole association.

On the card with the flowers, it says "We miss you"

I miss you Marcella. You were someone I could always talk to, somone who put up with me regardless of how I acted.

Flowers are not enough. They would not have been enough when you were alive to let you know how much you meant to me.

Goodbye, Marcella. Many people miss you and we all wish we had told you more often that we loved you. Goodbye.

"Network" Revisited

The movie "Network" was released in 1976 or 1977. The best recalled line is the anchor screaming out into a thunderstorm "I'm mad as hell and I'm not going to take it anymore!" In the movie, the anchor goes insane and is eventually assassinated. He expresses outrage, he expresses confusion, he expressesa lot of FEELINGS, but he never DOES anything with those feelings other than to convince a lot of other people that they feel the same way too.

I thought about it today while reading an article about the Tea Party. The article explained that while on the grass-roots level the Tea Party is helping people articulate their anger/frustration/whatever at government in general, one of their weaknesses is that they have no platform, no program for dealing with the frustration. They do tell people to go out and vote, and at times impliadly, at times expressly tell them to vote out the incumbents.

However, when it comes to what the new members of the legislative bodies will do, are expected or anticipated to do or would please the Tea Party by doing, the silence is deafening.

The Tea Party, like the anchor in Network, is screaming "I'm mad as hell, and I'm not going to take it anymore!" However, what they are going to do (and what is it they are not going to take) is never stated.

Unless they want to meet the modern-day equivalent of assassination (being forgotten and relegated to oblivion) the Tea Party needs to present CONCRETE objectives. They need to not merely express a desired result but to articulate definate steps to achieve those results.

They want less government? What do they think can be eliminated (and how much do they think such elimination would save?) Cut back the IRS? How will the government collect the tax monies to fund defense? Eliminate the Department of Education? With no National standards for math and science, how will the next generation compete in the jobs market? Eliminate the EPA? Who will force BP to clean up the next oil spill?

I am not saying that any of those aims are not achievable, or even not admirable. I just would like to know HOW they will be achieved.

Being mad as hell and not willing to take things might be a good starting point. However, without an idea of WHERE you want to end up, you are just running in circles.

Transitions

Just got back home from a week in San Diego (Spring Valley, to be precise) We moved my mother from independent living to assisted living.

We was myself, my two brothers, one sister-in-law, and one day; three cousins.

Mom has lived in this community since '02. She has been in independent living, with a two-bedroom, two bath apartment. Dad died in '04, and Mom has been on her own. She quit driving in '08, and gave her car to my niece.

We, (my brothers, my sister and I) had somewhat forbidden her from cooking for this last year. Three reasons: 1) her age, 2) here, she had an electric stove after 50+ years of gas; and 3) quite frankly, the stove was somewhat defective, as we determined when trying to cook things ourselves.

Cut down, cut down and delete! was the theme. Most of the furniture was already figured out. A few glitches occured. Her touch-turn lamps both failed during the move. We suspect that since they were roughly 30 years old, the only reason they were still functioning as designed was because they had not been moved in 8 years. She had sufficient other lamps.

My sister had done a crude layout for the furniture. She either over-estimated the space or under-estimated the size of the furniture. With four men present on Tuesday, we managed to re-configure.

We rented a storage space to store the pictures and decorative items my sister will arrive later this year to arrange. We rented a 5X5 space. It is not full. Because the stored items are mostly pictures and decorative items, they are mostly boxed, and my sister will have the delight of arranging them further.

We lucked out. We had called various charitable organizations about picking up un-needed items. They could not pick up while we were there. On Wednesday, I was running something between the old and new units. Saw a truck from the Rescue Mission picking up stuff. Asked them if they could stop by our place. They could, and took several large pices that we had worried about getting rid of.

Mom's next door neighbor (in independent living) has a daughter who has become a friend. Her church is having a rummage sale. She took a bunch of stuff for that.

I "scored" a tile-top table (mission style) that had belonged to Aunt Polly. In her will, I was to receive it. However, my mother got it from her before she died. Since it wasn't part of her estate, I didn't get it then. Steve and I have had a long-standing competition/joke about which of us took it. He let me have it. Steve got the silver service. I'm relieved. I don't have space to securely store it.

I got "the Rowe rock" This is a piece of black, only semi-crystaline tourmaline shot with granite that we picked up many, many years ago. I recall it as being on a truck-trail somewhere behind Lovelace damn. I could be wrong on the location. I do know that it was sometime in the early '60's, as I do remember it being loaded into the '57 Chevy wagon, which then hit bottom a couple of times on our way out of where ever we were. It is now in my front (xero-scaped) yard. As my husband noted, the New Mexico winds will NOT move it.

I took Mom's rain-guage, which is a frog with the rain-gauge tube in his mouth. It fits in my back-yard decor.

When we moved the folks out of the house in '02, it was very emotional. They had been ther for 50+ years. I was born after they moved there.

We knew that the house would be torn down, the orchard mostly razed, and four or five luxery homes built on the site. All four of us were there, and it was a major wrench.

This time, the wrench was cutting down on the memory items. I don't really mind the stuff I have bought since '02. It is the OLD stuff. I took several vases. Some of them were wedding presents in 1945. We stored the china that my grandmother painted.

Mom has moved from an apartment that was almost as big as the old house to a single room. Her memories have not shrunk. But her room for displaying them has.