I “can’t believe it”!

I met with L____ (our CPA) today so I could sign all our tax returns. (It’s an annual affair. We have about a dozen legal structures, many of which require separate tax returns.)

Anyway. So we’re talking about “how’s life,” as we usually do. (I enjoy meeting with L____ as a casual friend as well as counselor, and we talk about how things are going several times a year.)

So he asks me: “What do you think of J____’s proposal?”

I grow thoughtful for a minute and then say, “I think, in general, it sounds like a great idea. But Sarita and I are really concerned about his 501(c)(3) proposal. . . .”

“B____ [our estate planning and structures attorney] and I are very much concerned about the 501(c)(3) proposal,” he replied.

(!!!!) “You are?!? . . . J____ said you guys were all behind the plan!”

(!!!!) “We said we couldn’t support it unless we got a private letter ruling^* from the IRS.”

(!!!!) “J____ never said anything about a private letter ruling. . . .”

And so it went.

I “can’t believe” it! . . . And here I said of B____ and L____, last week, that, because, apparently, they had not raised any of the issues I had come up with concerning shifting to a 501(c)(3), they must not know enough about the issues. I “couldn’t believe” they hadn’t raised any concerns about the proposal. It’s just not like them. They are usually so sharp. –So to have me coming up with concerns that they didn’t mention: I concluded it could only be because 501(c)(3)s were definitely not their area of competence.

But now to have L____ say they specifically had raised concerns . . . !!!!

Why did J____ not say anything in response to my letter last week in which I basically suggested L____ and B____ must “simply” be (excuse the word!) incompetent . . . ?

I don’t understand this. And I am upset.

^* A private letter ruling is an official determination by the IRS concerning a taxpayer’s proposed course of action. I am told they are a pain to acquire; they can take “forever”; but if you have any question about whether your proposed course of action will be frowned upon by the IRS, you probably want to get such a ruling . . . or be prepared to take the IRS to court when they disallow (assuming they will disallow) your proposed action.

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This entry was posted on Monday, April 14th, 2008 at 3:06 pm and is filed under estate planning, legacy planning. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.