Strategic Corporate Social Responsibility

“When he remaining eBay in 2001, there is only one direction for a hesitant billionaire like him to mind in. “The partnership with a business college has allowed Skoll to provide formal MBA education to the people who may not ordinarily have been able to see it. … It’s a one-year MBA and there are five scholarships for these interpersonal entrepreneurs which come into the programme.

This doesn’t leave us much room to find even more in the Commissioner’s favor. To some small extent, however, the actual Commissioner argues increases problems with respect to objective and timing here. We trust him that the O’Neils’ decision not to pay their liability in 2007 when they seemingly could have demonstrates they either didn’t intend to pay it or were endeavoring to delay the day of reckoning.

This made the Commissioner spend considerable additional effort to understand this goverment tax bill satisfied. He was compensated for his time by additional accrued interest, however the O’Neils’ dodgery undercut the Commissioner’s interest in an orderly, quick, and efficient taxing system. This unlisted factor weighs a bit against finding alleviation. Because the Commissioner raised this discussion during his administrative review never, we won’t evaluate it under a limited standard and scope of review. Allison argues that it’s inequitable to deny her relief where the denial will indirectly benefit her ex-husband. While this unlisted factor has nothing to do with economic hardship, it can be an “equitable” argument.

The problem for all of us is how to include it in our balance. Once we noted, the Code makes jointly submitting spouses jointly liable for the tax. Congress itself balanced the equities of the policy choice when it enacted section 6013(d). The zero-sum problem that Allison shows here pertains to any ex-spouse who’s held responsible for the debt of the other ex-spouse. Allison raised this debate during her administrative review never, and as with the Commissioner’s “failure to pay the liability when they could” argument, we won’t assess this argument under a limited standard and scope of review.

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II. Conclusion We have already concluded that Allison isn’t eligible for relief underRevenue Procedure 2003-61’s safe harbor because the knowledge factor weighs against her. 3 (2d Cir. 1995) (talking about previous section 6013), aff’g T.C. The knowledge factor’s unique importance, see Haggerty v. Commissioner, T.C. 500 monthly in “gifts” from her ex’s family members, but she doesn’t include these in her calculations. Allison wouldn’t suffer financial hardship if forced to pay the 2005 taxes liability.

1.1 million relating to her declaration at the Appeals conference. It had been no mistreatment of the Commissioner’s discretion to think about this sizeable nonexempt asset when it identified Allison’s ability to pay without suffering financial hardship. This factor weighs against her no matter our range and standard of review. Significant Benefit The Commissioner now alleges that Allison will advantage beyond regular support by receiving a refund of the Orinda home sale proceeds.

Allison’s characterization twists this factor a little. It is true that Michael used the proceeds from his partnership’s big sale to Pulte to pay his expenditures. Orinda home. Michael was without doubt the biggest income source for the family in 2005, and money is fungible, so we find that Allison did in reality benefit, or indirectly directly, from the fundamental income. Whether this benefit was “normal” is another question.

Allison already cashed out partly when she and her hubby refinanced the Orinda home to allow her to continue to work only part time, to keep her in the house, and to pay back credit-card personal debt. And here the Commissioner again records that Allison intended to use the Orinda home’s sale proceeds and then fund her pension.

While a home might not be “beyond normal support,” pension money can be. See George v. Commissioner, T.C. 5. Reviewing the notice of determinationde novo, we buy into the Commissioner that factor weighs in at against alleviation. In the notice of determination, however, the Commissioner figured this factor neither favored nor disfavored relief, but was natural. Michael if the few experienced paid their fees. This conclusion was not an mistreatment of discretion.

Without knowing if the support Michael provided Allison increased as a result of the couple’s not paying their 2005 taxes liability, the Commissioner couldn’t tell if the support was regular or atypical. He was well within his discretion to conclude this factor was natural. In amount, under a de novo review, we conclude this factor disfavors alleviation; and on the record available to the Commissioner, he didn’t err to conclude it was neutral.