Questions for Mitt Romney: Magical Mormon Underwear. Lying for The Lord, Bigotry, Secrecy and Polygamy
Saturday, November 17, 2012
Saturday, November 10, 2012
Ding Dong the Mormon's gone
Thanks to the determination of millions of good people the Mormon has been stopped. The GOP and it's Mormon figurehead tried to stop the good people from voting but they only made us angrier and more determined. Cry in your beer, white power "conservatives." Your day is gone.
Karl Rove In Denial, Melts Down On Fox News, Attempts To Get Network To Rescind Calling Election
NOV 7, 2012 12:03 AM169,823 214
Karl Rove In Denial, Melts Down On Fox News, Attempts To Get Network To Rescind Calling Election
It's been a weird night at Fox News, and it got even weirder in the moments after every network, wire service, and amateur mathematician called the election for President Obama. That's because Fox News contributor Karl Rove—who spent millions attempting to get Romney elected—bizarrely refused to accept his own network's conclusion that Obama had won Ohio, attempting to string together a way in which Romney could could the Buckeye State.
His story grew more ludicrous as he continued talking, and even his on-air colleagues appeared to attempt to talk him out of continuing before Rove become a blubbering pool of, uh, blubber. Too late. [Fox News]
Tuesday, October 23, 2012
Friday, September 28, 2012
Lying Mormonette: Your tax dollars at work.
Stupid but refreshingly honest Mormon works for the county clerk registering Republicans to vote. Mormons: A dangerous right wing racist cult. Liars by religion.
Ooops. Unsurprisingly, there were questions for County Clerk and Recorder Wayne Williams, who just happens to be a Republican and according to his official bio at the El Paso County, Colorado website, “an active member of the Chapel Hills Ward of the Church of Jesus Christ of Latter-Day Saints where he currently serves in the Bishopric.”
And the young woman also just happens to be a Mormon. She is wearing a Mormon CTR ring, a type of ring given to children at baptism (CTR means “choose the right”):
Tuesday, September 18, 2012
Friday, August 24, 2012
GOP Texas Judge Predicts Civil War If Obama Wins
HURSDAY, AUGUST 23, 2012
GOP Texas judge predicts civil war if Obama wins
[Obama] is going to try to hand over the sovereignty of the United States to the UN. Okay, what’s going to happen when that happens? I’m thinking worst case scenario here. Civil unrest, civil disobedience, civil war maybe. We’re not just talking a few riots here and demonstrations. We’re talking Lexington-Concord take up arms and get rid of the guy.And I was able to confirm that he is in fact a Republican judge.
Now what’s going to happen if we do that, if the public decides to do that? He’s going to send in U.N. troops — with the little blue beanies. I don’t want ‘em in Lubbock County. Okay. So I’m going to stand in front of their armored personnel carrier and say ‘you’re not coming in here’. “And the sheriff, I’ve already asked him, I said ‘you gonna back me’ he said, ‘yeah, I’ll back you.’”
It's amazing how much Republicans hate our country. After all, they're the only one who keep talking about leaving? Hell, Mr. Romney's family did leave. They hate our system of government (they can't stand the separation of powers, especially an independent judiciary). They can't stand gays, women, blacks, Latinos. Other than the Second Amendment, they don't seem to like the Constitution much either.
They do like the flag, but that's only when they don't have to think very hard about what it actually stands for.
They claim to like the military, but they don't - just look at the way they treated John Kerry for winning a medal for saving his fellow service members. And the way they use our service members without much thought given to the lives they're putting at risk (Iraq comes to mind, and don't forget Bush's unwillingness to give our troops the body armor they needed). And they mock the commander in chief for having caught bin Laden.
So it figures Texans keep talking about leaving the US. They and their party left America behind a long time ago.
More Posts About: GOP Extremism, Racism
Thursday, August 23, 2012
Romney Just Lies- That's All - Mormonism is a great training ground for liars
See how mormonism is liarism- one example is yesterday's post--
http://www.thedailybeast.com/articles/2012/08/22/why-believe-romney-now-after-his-lies-on-medicare-bain-taxes.html
The Mormon Church Is Not A Corporation--Honest injun
http://www.thedailybeast.com/articles/2012/08/22/why-believe-romney-now-after-his-lies-on-medicare-bain-taxes.html
Why Believe Romney Now, After His Lies on Medicare, Bain & Taxes?
by Robert ShrumThe candidate this week added Medicare to his litany of falsehoods—on Bain Capital, his taxes, welfare, and debt, among many others. It’s now clear Romney will say anything. So why trust anything he says?
First, Paul Ryan placed Medicare on the chopping block. And amid the aftershocks of a bold and bad decision to put Ryan on his ticket, Mitt Romney this week also put Medicare on the lying block. Michael Tomasky is on target when he tartly observes that Romney is waging the “lyingest campaign ever”—and utterly demolishes the most “blatant” lie of all, that the president has gutted welfare reform. The third Romney ad leveling this charge brazenly cites a newspaper that was condemning the accusation.
The fabulation about welfare wasn’t just an expedient ploy for a candidate who was falling in the polls as he stumbled home from his malaprop-laden trip abroad. And the gyrations about Medicare weren’t just a one-off tactical response to a potentially mortal threat. Reckless disregard for the truth is a habit at the heart of the Romney enterprise. From the beginning, the entire campaign has been a calculated exercise in deceit. Its central rationale was conceived in a falsehood, that Romney the financial manipulator at Bain was a prolific job creator. The suspiciously round number was 100,000 jobs. The evidence? Romney never did disclose any records to back up his boast, and he took credit for hiring at companies long after Bain was gone from them—and he was gone from Bain.
Then, when the Obama campaign’s Bain ads hit, similar to the ones that upended Romney in a Senate contest with Ted Kennedy in 1994, the former governor was still unprepared, presumably unable to disprove the criticism or prove his self-defining claim. He retreated first to bromides about free enterprise, and more recently to a cop-out plea for an “agreement between both campaigns” to declare that attacks on “business or family or taxes” are off-limits. What’s family got to do with job-crushing profiteering, offshore tax havens, or Swiss bank accounts? It was Romney who ran on his business experience. Suddenly it’s unfair to talk about it.
He doesn’t want to talk about his taxes, either, although he finally and conveniently asserted that the returns he was refusing to disclose revealed he had always paid about “13 percent.” Now, that rate for a guy with an income of $20 million is hardly a profile in fairness. But if he did pay something more than 1 or 2 or 5 percent, or more than zero, then why not make the returns public? There’s more than a chance that his expedient reassurance is a ruse. As Ann Romney blurted out, the “reason we don’t disclose more is…it will just give them more ammunition.”
Paul Ryan campaigns with his mother as he discusses Medicare in Florida.
From Bain to welfare and taxes, Romney’s bodyguard of lies wasn’t doing much to protect him. So he must have hoped that by announcing Ryan as his running mate, he could change the subject. It sure did. Instantly the focus shifted to the Ryan planto “save” Medicare by destroying it, replacing the guaranteed benefit with a voucher plan that would cost seniors more, push many of them into private insurance, and force others into HMOs. This is not a path to victory in November. And in the ensuing controversy, the Ryan-Romney ticket—after all, Ryan is the substance behind the shape-shifter—looked like the Keystone Pols caught up in a mayhem of fraud.
One Republican operative, a genuine conservative who thinks Romney isn’t genuine at all, renders his verdict: “He doesn’t believe in anything but his own ambition.”
Romney had hailed the Ryan plan as “marvelous” during the primaries and pledged to sign it as president, a pledge one of his advisers reiterated the day after the Ryan pick. Just hours later, Romney tried to back off in an interview on 60 Minutes: “Well, I have my budget plan…and that’s the budget plan that we’re going to run on.” But that plan, it soon turned out, was not all that different. Or as Romney told a Green Bay radio station, “Paul Ryan's and my plan for Medicare, I think, is the same, if not identical—it’s probably close to identical.” You think? Can’t Romney ever talk straight? He’s not supposed to; as one of his strategists told Politico, it would be “politically unwise” to let voters see the “detail” of his proposal.
While dissembling about his own position, Romney counterfeited Obama’s, alleging in a hastily edited spot that the president “cut $716 billion from Medicare…[t]o pay for Obamacare.” Haste, and the taste of impending political doom lay waste to the truth. Obama didn’t cut one dollar from Medicare benefits, but payments to providers like hospitals with a poor record of patient care and insurance companies that haveinflated the cost of Medicare Advantage, a Bush-born private supplement that suggests how inefficient and expensive for seniors Ryan’s vouchers would be. Moreover, the accurate figure for the savings is $500 billion; Politifact was moved to ask where Romney the vaunted numbers man found Obama cutting another “$200 billion while no one was looking.” Undeterred and determined to lie his way out of trouble with seniors, Romney doubled down. The president, he said, has “robbed” Medicare.
The other truth that has been trashed here is that the Ryan budget includes exactly the same savings that Obama signed into law. Ryan just uses the savings to lavish a tax bonanza on the top 1 percent. Obama uses them to prolong the solvency of the Medicare trust fund and to close the “doughnut hole” in prescription-drug coverage for Medicare recipients, which required them to pay 100 percent of their annual drug costs between $2,840 and $6,448. The difference here gives the lie to the Ryan-Romney ticket’s reassurance that their scheme would mean “no changes…for current seniors or those nearing retirement.”
First, by repealing Obamacare, the GOP duo would reopen the doughnut hole and cost millions of the elderly thousands of dollars.
Second, as Romney dug himself in on the $716 billion whopper, he tried to extract credibility from contrivance by promising to reverse the Obama “cuts.” He’s straining to leave the misimpression that this would benefit seniors when in truth it could leave Medicare insolvent by 2016, threatening a reduction in benefits sooner not later—and not for the next generation, but now. Yet there was the invincibly misleading candidate standing at a white board—what a perfectly corporate image—scrawling “Solvent” across it.
Third, the immediate Medicaid cuts that Ryan has proposed and Romney has endorsed would shred coverage for 6 million of the elderly, many of them in nursing homes, who account for 23 percent of the program’s cost.
As the Obama camp fired back on the airwaves with an indisputably accurate refutation of the notion that the president ever cut benefits, Ryan appeared in Florida alongside his mother acting out the National Republican Congressional Committee’s playbook, which advises: “Inoculate by pledging to secure and protect Medicare; use credible third-party validators (moms or seniors).” It was a cynical and duplicitous ploy to put a kindly face on a cruel and selfish policy. And of course, Ryan’s mother could afford to pay thousands more for prescription drugs—or an extra $6,000 for Medicare.
Expect a lot more on the Medicare front. The winner in this contest—between an accurate description of a plan the Republicans can’t defend and their disinformation about it, and the president’s position—is likely to win in November. And that’s because, as I’ve argued before and the last week has confirmed, Medicare has become the leading edge of the defining choice in this election: who fights for the middle class, and who favors the few?
As the Medicare battle intensified, Romney and his Republican allies took a little time to concoct another charge and then exploit it, with a leak that was a tawdry lie.
In response to the altogether obvious reaction that their crooked welfare ad had a racial subtext—look at that African-American president going easy on giveaways for you-know-who—the Romney campaign accused Vice President Joe Biden of using a “codeword.” His offense? He said Romney’s “gonna let the big banks once again write their own rules. Unchain Wall Street. Put y’all back in chains.” The accusation was risible coming from the party of the codeword, of Nixon’s “Southern strategy” and immigrant-bashing. It was also ludicrous since Ryan and House Speaker John Boehner have both invoked a similar metaphor, about “unshackling” the economy.
The controversy provided the pretext for Matt Drudge, Romney’s unofficial press secretary, to revive and flog another fiction, that the White House was anxious toforce Biden off the ticket in favor of Hillary Clinton. The source? The pseudo-journalist Edward Klein, who was said to have “sources deep in the Clinton camp,” an incredible notion given that Klein has previously written a foul book about Clinton roundly denounced by liberals and conservatives alike. This “sordid volume,” this “trash” this “smear”, as conservative columnist John Podhoretz searingly described it, reported that Chelsea Clinton was the product of a marital rape.
Klein had no credible source then for his lowlife reporting, and he has none now for his latest excursion into political make-believe. As the secretary of state’s spokesman emailed The Weekly Standard: “Ed Klein’s motto is ‘If at first you don’t succeed, lie lie again.”
Of course Biden’s place on the Obama ticket is secure. The vice president is, as he was in 2008, a decided electoral asset in Pennsylvania, Ohio, and Florida. He connects with blue-collar Democrats, and he’s one of the president’s most trusted advisers. The purpose of the right wing’s exercise in sideshow fantasy was to disrupt the Obama campaign and to devalue Biden as a campaigner. I don’t think either ploy worked.
The episode was made out of a whole cloth, but it is another thread in the GOP’s scarlet fabric of fraud.
Doesn’t the other side do the same thing? No, Obama and his supporters don’t. The worst alleged against them is a super-PAC commercial in which Joe Stopic, a former steelworker at a company taken over by Bain, discusses the loss of his job and his health insurance, which left his wife without coverage when she had cancer. The story is more detailed than that, probably too detailed for a 30-second spot. But the bottom line is true: if Stopic’s job hadn’t disappeared while Bain and Romney made money, his wife would have had insurance when she needed it.
We ought to reject any false equivalence between the Obama and the Romney campaigns. There’s nothing in modern presidential politics that quite equals the audacity and scope of Romney’s long march of lies.
His first commercial in the primaries was a giant step into the dark side. It twisted a 2008 speech from Obama in which he was quoting “John McCain’s campaign” as saying: “If we keep talking about the economy, we’re going to lose.” The Romney ad excised the reference to McCain, leaving the impression that the words were Obama’s and the time was now. The spot was a finely edited piece of Orwellian double-speak straight out of 1984.
Or take Romney’s constant refrain that the president is responsible for “an inferno” of “debt and spending.” That’s flat-out wrong. Under Obama, annualized growth in federal spending has risen at the slowest pace in decades. Debt and deficits have been driven primarily by Bush’s tax cuts, Bush’s unfunded wars, and the Bush economic collapse of 2008. Despite the Obama stimulus, the rate of increase in federal spending was even higher under Herbert Hoover. And if the House GOP hadn’t stymied Obama, there would have been additional job-creating stimulus; the recovery would be more robust; and Romney’s prospects would be even more anemic than they are.
The list could go on and on. One Republican operative, a genuine conservative who thinks Romney isn’t genuine at all, renders his verdict: “He doesn’t believe in anything but his own ambition.” Maybe that’s why Romney will say anything. But why, then, should we believe anything he says?
I don’t think the country will buy this phony campaign from a patently phony candidate. He’s struggling despite the economic headwinds fanned by his own party’s obstructionism in Congress. So come this November, just maybe a re-elected Joe Biden will say, fairly and accurately, that our politics has been unshackled from Romney’s chain of lies.
Like The Daily Beast on Facebook and follow us on Twitter for updates all day long.
Shrum, a Senior Fellow at NYU, was a longtime political consultant who worked on numerous Democratic campaigns, including Kerry-Edwards in 2004 and Al Gore’s 2000 race for the White House.
For inquiries, please contact The Daily Beast at editorial@thedailybeast.com.
Wednesday, August 22, 2012
The Mormon Church Is Not A Corporation--Honest injun
LDS Inc. owns .7% of Florida
My brother-in-law came to visit last weekend. As science geeks, we tried to see a shuttle launch while he was here (the launch was canceled 11 minutes before liftoff because of weather – ugh!). On the way to watch the launch we stopped by Deseret Citrus and Cattle Ranch to see the Mormon Church’s ranching operations:
Alas, as former Mormons, we failed to consider that they wouldn’t offer tours on Sunday. But we stopped by the Visitor’s Center anyway and drove around a bit. Here’s the Visitor’s Center:
I knew from the Deseret Ranches’ website and this wikipedia page that the ranch was big, but actually driving around the ranch made me wonder just how big it is. So, I spent a good 10 hours or so trying to see if I could map out just how big the ranch is. After all that time, I realized it was simply too big for me to easily map out by myself. But, the research I did do provided me with some fascinating information.
First off, thanks to a corporation registration website in Florida, I was able to track the name changes of the holding companies for the ranch over the years, eventually finding the current name. It used to be Deseret Properties of Florida, Inc., Deseret Farms, Inc.,Deseret Farms Inc., Deseret Ranches of Florida, Inc., Deseret Livestock Company, Deseret Properties of Florida, Inc., Deseret Ranches of Florida, Inc. (1), Deseret Ranches of Florida, Inc. (2), but it is now called Farmland Reserve, Inc.. Once I finally found the current holding company, I was able to visit the property tax appraisers’ websites for the three main counties where the ranch is located: Osceola, Orange, and Brevard. On those sites I found all the property listings of Farmland Reserve, Inc. Here’s a summary of what I found after I added them all up:
County | Acres | Value |
Osceola | 182,685.50 | $763,252,812.00 |
Orange | 64,843.57 | $208,286,252.00 |
Brevard | 41,559.66 | $12,552,680.00 |
Hillsborough-FRI | 3,952.94 | $30,145,012.00 |
Total | 293,041.67 | $1,014,236,756.00 |
Yep, you’re eyes do not deceive you – LDS, Inc. has more than $1 billion in for-profit property in Florida. The acres convert to 457 square miles, or .7% of the State of Florida. I can’t say for certain, but my guess is that LDS, Inc. is the largest landholder in the state behind the government. For comparative purposes, Disney owns 25,000 acres (that’s all of their properties, not just Disney World), or about 1/12th of the land owned by the LDS, Inc. holding company.
To tally all of this information, I actually built a spreadsheet that you’re welcome to download and peruse. I also started drawing the land parcels in Google Earth, but once I realized just how many there were, I decided I just didn’t have the time. I did complete all the land in Orange County and started on the land in Osceola County. If you want to see the maps or, better yet, if you’d like to improve/complete the maps, you can download them here: Orange County, Osceola County. If you do download them and improve them, please send me a copy of the updated versions as I’d like to have them.
As I was searching through these listings, on a whim I decided to see if Farmland Reserve, Inc. owned any property in my county, Hillsborough, FL, which is all the way across the state from Osceola and Brevard Counties. Turns out they do (see above table). That’s in addition to the $12 million owned by “Church of Jesus Christ of Latter Day Saints Corporation”, which is the company that holds the churches. This makes me wonder just how much property Farmland Reserve Inc. owns. I checked a couple additional counties in Florida but didn’t find any more property.
One of the reasons I wanted to visit the ranch is because my aunt and uncle recently completed a mission there (I should have gone while they were there, but never made it). The amazing thing about the fact that they served a mission there is that they did zero proselytizing and they paid to serve their mission. So, what did they do? My uncle was a high school shop teacher. He knows how to build and repair homes. So, they put him to work building homes on the ranch. He’s round 70 years old and was working 12 hour days 6 days a week for 18 months. His wife ran some of the tours and did other odd jobs around the ranch. When I found out that my aunt and uncle were paying for the opportunity to work for Farmland Reserve, Inc., a billion dollar for profit company, I was not very happy. Not only did the LDS Church use tithing money to buy the ranch (I’m assuming, maybe it was profit from some other business venture), but now it makes people pay for the opportunity to make one of their subsidiaries money. How is that at all ethical?
To wit, the obvious question is: How does the billion dollar ranching operation of the LDS Church further its religious aims? Why does a religion need a billion dollar ranch? Anyone?
Finally, all this searching around for property owned by LDS, Inc. led me to realize that we, the MSP community, could probably put together a pretty good estimate of the property holdings of LDS, Inc. (in the US at least) fairly easily if we distributed the work among us. If each person looked up the holdings of LDS, Inc. in their county and put them in a spreadsheet, we could aggregate them and keep a running total of known property value of the LDS religion. It would make a cool little widget for MSP to display. Thoughts?
Views: 13636Tuesday, August 21, 2012
Romney Has Zero Percent Support From African Americans In New NBC/WSJ Poll
Free Republic
http://www.freerepublic.com/focus/f-news/2921325/posts Browse · Search | News/Activism Topics · Post Article |
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Mediaite ^ | August. 21, 2012 | Meenal Vamburkar
Posted on Tue Aug 21 2012 21:43:52 GMT-0400 (Eastern Daylight Time) by Free ThinkerNY
A new NBC/WSJ poll out Tuesday shows President Barack Obama with a four-point lead over presumptive GOP nominee Mitt Romney. But as is often the case with polls, some of the more interesting numbers were in the details. For example? Romney snagged zero percent of African-American voters.
Among key demographics, the poll noted that Obama had a lead over Romney. The most stark being when it came to African Americans: 94 percent to 0 percent. Via NBC:
Looking inside the numbers, Obama continues to lead Romney among key parts of his political base, including African Americans (94 percent to 0 percent), Latinos (by a 2-to-1 margin), voters under 35-years-old (52 percent to 41 percent) and women (51 percent to 41 percent).
His lead among those groups isn’t surprising, but hard for the number zero not to catch a person’s attention.
(Excerpt) Read more at mediaite.com ...
Sunday, August 19, 2012
Friday, August 10, 2012
Romney, Marriott And Son Of Boss ---- For Dummies
Peter J Reilly, Contributor
I focus on the tax issues of individuals, businesses & more
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Now that the question of Mitt’s knowledge of Son of Boss deals has been raised by CNN, I thought it might be a public service to explain Son of Boss deals. A lot of commentators seem to think that they are too hard to understand, but I don’t think so. I’ve told my friends at Dogs Against Romneythat they might not want to bother filling in the beagles and the mastiffs , but I think the border collies and the poodles are ready for it.
Basis
I have previously explained Son of Boss using the ill fated tax shelter of EMC founder, Richard Egan, who got into the game in its waning days. His advisor, Stephanie Denby, commented on the beauty of the deals:
Secondly, some of the transactions focus on generating basis as opposed to capital loss. Basis is more discrete [sic] and less likely I believe to cross the IRS radar screen.
Secondly, some of the transactions focus on generating basis as opposed to capital loss. Basis is more discrete [sic] and less likely I believe to cross the IRS radar screen.
We are taxed on income, not gross receipts. That means that when you sell something you get to deduct your basis. In its simplest manifestation basisis the amount of money that you paid for something. You buy something for five dollars and sell it for six, your income is a dollar. Of course it can be more complicated if you acquire assets in other ways, such as by gift or inheritance or in a like-kind exchange. The important point though is that when you sell something the higher your basis the less your gain or the greater your loss.
Once you own something though it is kind of hard to increase its basis. If it is a partnership interest you increase your basis by the income that flows through to you, so your gain will be less if you sell the partnership interest, but that is like hitting your head against the wall because it feels so good when you stop. If it is a tangible asset, you could spend money to improve it, but that doesn’t really feel that satisfying. Of course, if it is an appreciated asset, you could die, but that is kind of extreme. The way that the designers of the Marriott deal came up with involved combining two things each of which is only slightly complicated – short sales and the formation of a partnership. Here is a link to the decision if you want to follow along, but I’ll try to break it down for you.
Short Sales
When I was a kid, my father used to tell me jokes. There was a problem though. He worked on Wall Street. He did not have a particularly lucrative career (He was a senior order clerk) but he had a Wall Street sensibility to him . So the jokes that he told me were incomprehensible to an eight year old. One of them that I finally got when I was about thirty, was his little ditty about short sales “He who sells what isn’t hissen, buys it back or goes to prison.” The important tax principle is that the proceeds of a short sale are not gross income. You recognize gain or loss when you close the short sale.
Partnership Formation
When you put stuff into a partnership, the partnership’s basis in the stuff is your basis in it. You increase your basis in your partnership interest by your basis in the stuff you put in. Another important principle is that your share of the liabilities of a partnership is part of your basis in the partnership. If you increase your share of the liabilities it increases your basis, but if it decreases it reduces your basis, just as if you took out cash. Your basis can never go below zero. If a loss allocation would drive it below zero, the loss is suspended, but a liability decrease, like a cash distribution, will cause you to recognize gain. If you put leveraged property into a partnership and the liability shifts away from you or is paid down by the partnership, you may end up recognizing gain.
Now you are ready to do your Son of Boss deal. Here are the steps:
Marriott International sells short two-year Treasury notes and invests the proceeds in five-year Treasury notes. Marriott International, as a limited partner, and a third party, as the general partner, form a partnership.Marriott International contributes the five-year Treasury notes, subject to the short-sale obligations, to the partnership and the general partner contributes some cash. The partnership obtains additional assets and subsequently sells the five-year Treasury notes and closes the short sale obligation on the two-year Treasury notes.
Marriott International sells short two-year Treasury notes and invests the proceeds in five-year Treasury notes. Marriott International, as a limited partner, and a third party, as the general partner, form a partnership.Marriott International contributes the five-year Treasury notes, subject to the short-sale obligations, to the partnership and the general partner contributes some cash. The partnership obtains additional assets and subsequently sells the five-year Treasury notes and closes the short sale obligation on the two-year Treasury notes.
Marriott International transfers its partnership interest to another Marriott subsidiary.
No gain or loss is recognized on the transfer, but the partnership-interest transfer results in a technical termination of the partnership which causes a deemed distribution of the assets to each partner and a re-contribution of the assets to a new partnership.
The tax basis of the assets takes on the “outside” tax basis of Marriott International’s interest, i.e., the value of the five-year Treasury notes Marriott International contributed to the first partnership, which value is not reduced by the short-sale obligation.
The tax basis of the assets takes on the “outside” tax basis of Marriott International’s interest, i.e., the value of the five-year Treasury notes Marriott International contributed to the first partnership, which value is not reduced by the short-sale obligation.
The remaining additional assets later are depreciated or are sold, and Marriott International recognizes the resulting tax losses.
I always had a hard time understanding these deals, because of my training as an accountant. You can’t get the damn thing to work without an unbalanced entry. Essentially though the money that Marriott got for the short sale allowed it to buy something that it had basis in. Marriott argued that the obligation to cover the short sale was not a liability as defined by Code Section 752. So even though it didn’t really have to come up with any money out of its own pocket, it had basis in the partnership interest. The rest of the maneuvers are a little technical, but essentially the free basis gets shuffled around until it is actually used. In Richard Egan’s version of the deal EMC stock was contributed to the partnership that had been created. The IRS and the Court’s didn’t put it the way a confused accountant would – “Ok, I have a debit, now what the hell am I supposed to credit ?”, but they essentially got to the same bottom line -
The initial short sale, which generates the cash proceeds, and the subsequent covering transaction are “inextricably intertwined,” because under Regulation T the proceeds are chained to the obligation to close the short sale. Thus, the proceeds of the first step in the short sale transactions are also subject to the uncertainties of closing the short sale. In short, if contribution of the proceeds of the short sale increased the partners’ outside basis, the contribution of the obligation to return the Treasury notes that had been sold short required a decrease in the partners’ outside basis.
I never ran into these deals in their heyday. If I had I would have scratched my head, but I might have bought into it because of the letters from the tax attorneys who are supposed to know this stuff better than I do even if they don’t know a debit from a credit. So I would not be shocked if Romney did one of these deals for himself. Presumably the statute of limitations would be closed. That didn’t stop Tim Geithner from paying for his mistakes though. If Romney did do a Son of Boss deal, it really does not tell us anything about him that we do not already know, but if we want to hold him to the Geithner standard, he should pay regardless of the statute of limitations.
You can follow me on twitter @peterreillycpa.
I never ran into these deals in their heyday. If I had I would have scratched my head, but I might have bought into it because of the letters from the tax attorneys who are supposed to know this stuff better than I do even if they don’t know a debit from a credit. So I would not be shocked if Romney did one of these deals for himself. Presumably the statute of limitations would be closed. That didn’t stop Tim Geithner from paying for his mistakes though. If Romney did do a Son of Boss deal, it really does not tell us anything about him that we do not already know, but if we want to hold him to the Geithner standard, he should pay regardless of the statute of limitations.
You can follow me on twitter @peterreillycpa.
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