Thanks for the comments.

I will do another Son of BOSS post soon. I was suprised at how much interest there is in this topic.

The next one will be more detailed . . . for the true tax geeks.

Glad you enjoy the blog and I hope you come back.

I didn’t publish your last email because of the extremely vuglar and slanderous comments you made in it.

I suggest counseling.

It has to be tough going through life that miserable.

Good luck and God speed.

We are making progress.

First I was “uh,” then I was “dude,” now I’m “Dude” with a capital “D.”

By the time I’m finished with you, you’ll be calling me “Your Lordship.”

Summer’s article is incomplete and so is my blog post. It would take a 3 volume treatise to explore and explain all of the various incarnations of Son of BOSS.

I will check out the Fulcrum case. I find it hard to believe that a court actually found there was no economic substance and still allowed the loss.

Keep coming back, Sir Whistlewhat.

You’ll keep me on my toes.

Regards

I forgot to add that if the S.O.B. has economic substance it ain’t a tax shelter.

Ted Turner’s transaction obviously did have economic substance.

And that should answer your question about a reasonable prospect of recieving a return on investment (i.e. profit).

I guess “dude” is a step up from “uh.”

Thank you for your politeness.

I agree the S.O.B is about contingent liabilities. That’s why I wrote this:

This is, of course, an exaggeratedly simplified version of the S.O.B. scheme.

The typical S.O.B. shelter involves the use of offsetting stock or currency options and the artificial step-up in basis is achieved by exploiting a since closed loophole in the tax code involving contingent partnership liabilities.

For a more complete explanation of the workings of these kinds of tax shelters I recommend you read The Son of Boss Shelter, by Robert L. Sommers.

kudos, for at least printing my response. P.S., in 1999 the IRS gave Ted Turner a $75 million sob deduction in Fulcrum Financial Partners via settlement for a transaction the DOJ and IRS alleged in court filings had absolutely no economic substance and were shams.

Uh, if you think I am wrong, it might be helpful to my readers if you regaled them with the correct interpretation of the workings of a Son of Boss tax shelter.

That might be more convincing than simply declaring, “uh, you are wrong.”

Don’t get me wrong, I do appreciate the sarcasm of the “uh” utterance. A very nice touch, indeed.

I will stand by my post until I hear your detailed critique of why and how it is incorrect.

With baited breath, I am . . .

Respectfully yours.

Thanks for stopping by.

You lie down with dogs, you wake up with fleas.

The other issue, of course, is if Mr. Bull doesn’t repay the Promissory Note doesn’t he have forgiveness of debt income?

That’s why the example I used is extremely simplified.

The actual S.O.B. transactions are more complex and, I assume, deal with the debt collection and debt forgiveness problems.