PAOO Greatest Hits

Originally published on Passive Activities and Other Oxymorons on December 2, 2010

I started this blog on December 28, 2009. I seeded it with a couple of unpublished articles I had written. One was of some practical import on the necessity for scrupulous transaction discipline if you wanted to have family limited partnerships respected. The other is on the tax aspects of transactions in the virtual world. The latter is currently of no practical value, but its time is coming. The blog did not begin in earnest until June of this year. I soon adopted a Monday, Wednesday, Friday schedule and a discipline of tying the posts to specific recent developments (sometimes the rope is pretty long).

Google provides me with a wealth of statistical information so I am able to identify the posts that have generated the most traffic. I'm relatively pleased with the ranking based on the peoples choice. The actual number of hits are of course a deep proprietary secret, but I feel safe in releasing the relative ranking. So the top five all time greatest posts based on traffic are


1.Does Tax Court Ruling on Gender Reassignment Go Far Enough ? This post owes its popularity to a plug from distinguished science fiction author and fellow Son of Xavier , John Sundman. I find it particularly gratifying. I am the longest serving board member of Just Detention International, formerly known as Stop Prisoner Rape. SPR had filed an amicus brief in the landmark decision Farmer v Brennan and frequently quoted the comment of Justice Blackmun:

The horrors experienced by many young inmates, particularly those who, like petitioner, are convicted of nonviolent offenses, border on the unimaginable. Prison rape not only threatens the lives of those who fall prey to their aggressors, but is potentially devastating to the human spirit

The plaintiff, Dee Farmer, was a pre-op male to female transsexual imprisoned in the general population of a male federal penitentiary. Transgendered persons, who are generally imprisoned based on their original biological gender, are among the groups most vulnerable to sexual exploitation in prison. So my work with JDI has made me sensitive to their issues.

The other thing that fascinates me about the case is that the taxpayer Rhiannon G. O'Donnabhain had changed her name from Robert Donovan. Is there some sort of connection between going from male to female and Irish American to Irish ?

2.Windfall For Unmarried Couples In this post I introduce Robin and Terry, the couple of indeterminate gender and marital status who were created to help me avoid awkward pronoun problems. The post concerns CCA 201021050 which discusses the federal tax implications of California community property laws on registered domestic partners. The ruling had received very little attention when I posted it. It may have been overshadowed by Perry vs. Schwarzenegger. I was also visiting California at the time so I was waiting for the call to be interviewed by Ellen. The call still hasn't come. My Robin and Terry posts did motivate an old friend to dub me "Friend of the Homosexual". I asked him if that was an official designation and he indicated it was so since then I have indicated that this is an "award winning" blog.

3.IRS To Stop Lousing Up Short Sales As I am writing, this post is still climbing. It is the closest I have come to a scoop. It concerns PMTA 2010-058 which relaxes IRS policy on releasing liens in short sale situations. It seems like there should be some interest in it and I have gotten some feedback that it is significant, but as of now (December 2, 2010), I seem to be the only person writing about it.

4. Incentive to Innovate This post deviated from my "current development" policy. I was at Mass Innovation Night and was surprised to learn that the special tax treatment of patents is not nearly as well known as it should be in those circles. The high traffic to this post was probably due to reciprocity since I mentioned a couple of presenters..

5. It's Over This was one of my favorites so I'm glad it did well. It concerns the failed tax shelters of EMC founder Richard Egan. It got me on a roll of historic metaphors and reflection on the tax business.

I have really enjoyed working on this blog and hope that you have enjoyed it also.