The writer of the Gloom, Boom & Doom Report, urged investment specialists at the CFA Institute Conference in Chicago that 25 percent of a portfolio should be assigned to gold given the very significant risks facing investors today. Faber said rates are so low that investors can’t generate income in bonds so they keep buying stocks and shares even though the prices are extremely inflated.
Central banks want to increase stock prices to make people feel rich and therefore spend their money, but the final result is income inequality and investor resentment, he said. “Faber told the investment professionals collected in Chicago that they shouldn’t be prejudiced against platinum. Although the typical investment pro continues significantly less than 1 percent of his or her portfolio in silver, Faber suggests 25 %. He views it as security from an unhealthy combination of great government debt and massive bond-buying by central banks globally trying to fight off a downturn with near-zero interest rates. “It’s ludicrous to believe that slashing rates shall get people to spend.” When rates are low, he says, you feel insecure as savings earn nothing. So, “you save more” based on the Chicago Tribune.
Ultimately the higher courtroom in Pennzoil made the decision that though Pennzoil may have met many of the requirements of Code Section 1341, it was not entitled to 1341 treatments. The Pennzoil Courts both stated that the language of §1341 requires the Plaintiff to demonstrate that five factors have been met: The emphasis provided below was the Courts. As will be talked about, a divided Appellate Court with one dissent believed the main reason to deny Pennzoil the advantages of the Mitigation section was under a different exception to the Mitigation provision.
These requirements seem to be relatively self-explanatory and certainly there can be no question about the interpretation of the fifth necessity. However, several of these requirements are not as ahead as they look straight. Each needs to be understood within the tax world, where often there are exceptions to ensure special provisions, like the Mitigation provision, applies, and then the ones that are legally deserving of them. Both Courts in Pennzoil addressed this two-part question, first by determining if the Taxpayer possessed an “item”, and then whether that item was “included in revenues.” I.R.C.
Guidance as to what is an “item” of revenues is situated in the I.R.S. Code Section 61. That Code Section provides a specific definition for revenues and an over-all one. Another Code Section, Section 161, has an allowance for deductions that are also specifically shown in the Code.
Except as otherwise provided. 13. Income from a pastime in an estate or trust. It appears that there could vary tax treatments as the Mitigation provision is concerned insofar. The “profits” that induce the false Income in some Ponzi Schemes may be excluded from the Mitigation problem because they’re a result of phony “inventory sales”. However, it is normally going to be more likely that “phantom income” (income that hardly ever really existed) will consist of interest, dividends, or many of the other items shown as income in the Code Section.
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4.4 Million obligations to repay suppliers consequently of Pennzoil’s alleged price fixing was from the same circumstances as the initial inclusion of funds. However, the Appellate Court reversed the low Court and differed concerning whether Pennzoil’s refund met the same circumstances test. ” Section 1341 is an exception to the state of right doctrine. The “same circumstances” test, developed by the Tax Court, “provides appropriate, workable limits” to that exception. Several examples were shown of the principle.
In the Bailey case, the taxpayer received dividends, salary, and bonuses as the officer of a corporation, and later paid a civil penalty for violating an FTC order in the ongoing work he did for the company. The taxpayer claimed that his payment of the penalty restored something of income contained in his revenues in previous years.
