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A Supreme Court dispute over a $15,000 IRS bill may be aimed at a never-enacted tax on billionaires_我的网站

一 |     WASHINGTON -- Charles and Kathleen Moore are about to have their day in the Supreme Court over a $15,000 tax bill they contend is unconstitutional.The couple from Redmond, Washington, claim they had to pay the money because of their investment in an Indian company from which, as Charles Moore, 62, said in a sworn statement, they “have never received a distribution, dividend, or other payment.”But significant parts of the story they have told to reach this point seem at odds with public records.The Moores are the public face of a high court case backed by business and conservative political interests that could call into question other parts of the U.S. tax code and rule out a much-discussed but never-enacted tax on wealth. The case is set for arguments on Dec. 5. The Moores are the latest example of plaintiffs whose lawsuits seem to simply be exercising their legal rights, but whose cases are backed by others with enormous amounts of money or a consequential social issue at stake. The Moores sought help from the anti-regulatory Competitive Enterprise Institute.Underscoring the case's importance at a recent Heritage Foundation event, lawyer Paul Clement said, "The constitutionality of a wealth tax may well be decided in the context of this case.”Details of the Moores' involvement with the company, initially called KisanKraft Machine Tools Private Limited, were first reported by Tax Notes, which caters to tax professionals. The public documents are filings with the Indian government.At issue in the case is a provision of the 2017 tax bill enacted by a Republican-controlled Congress and signed by then-President Donald Trump. The law applies to companies that are owned by Americans, but do their business in foreign countries. It imposes a one-time tax on investors' shares of profits that have not been passed along to them, in order to offset other tax benefits. The measure is expected to generate $340 billion in tax revenues.The Moores, along with the U.S. Chamber of Commerce and conservative think tanks, contend that the provision violates the 16th Amendment, which allows the federal government to impose an income tax on Americans.The $15,000 tax bill was for the Moores' share of KisanKraft's profits."If you haven’t received any income, how can you be required to pay income taxes?” Charles Moore asks in a video posted by the Competitive Enterprise Institute.But far from being a passive investor with no influence over the company, Moore, who worked at Microsoft during his career in software development, served on KisanKraft's board of directors for five years.“The story the Moores told about Charles' involvement with KisanKraft is directly at odds with the fiduciary responsibilities of an individual holding a board seat for an Indian company,” Mindy Herzfeld, a professor of tax practice at the University of Florida law school, wrote in Tax Notes.And there are other indications of Moore's more extensive involvement with KisanKraft than his testimony indicated. The company paid for his travel to India four times and he made at least two investments beyond the $40,000 stake he put up in 2006.Moore also was prepared to invest an another roughly $250,000. That money was ultimately returned by KisanKraft, along with 12% interest.One other inconsistency is that while the Moores say they jointly invested the money, only Charles Moore's name appears in company documents.The couple and their lawyers did not disclose any of that information in legal filings in three different federal courts, including the Supreme Court.“The original declaration on which the case is built is full of lies,” said Reuven Avi-Yonah, an international tax expert at the University of Michigan law school.In a brief conversation with The Associated Press, Kathleen Moore said she and her husband would not discuss the case and referred questions to their lawyers. Andrew Grossman, the Moore's lead attorney, did not respond to messages seeking comment.The omissions, along with the Moores' failure to take advantage of other legal options that would have deferred, if not eliminated, their tax liability make Avi-Yonah and other experts in international tax law suspect the case was manufactured to get at a larger issue, the tax on billionaires that has been proposed by some prominent Democrats but never enacted.A wealth tax would apply not to the incomes of the very richest Americans, but their assets, like stock holdings, that now only get taxed when they are sold. “There really was no reason for the court to take it on, other than to send a signal to warn off the Congress from passing a billionaire tax," said Steven Rosenthal, a senior fellow at the Urban-Brookings Tax Policy Center.Other provisions of the tax code could be upended by the court's decision, including measures relating to partnerships, limited liability companies and other business formations, Rosenthal said.Changes to those provisions also could affect some justices' finances. Chief Justice John Roberts holds a one-eighth interest worth up to $15,000 in an Irish partnership that owns a cottage in county Limerick, Ireland, and Justice Clarence Thomas' wife, Ginni, owns a limited liability company that generated between $50,000 and $100,000 in income last year from Nebraska real estate, according to the justices' financial disclosure forms. Two other recent Supreme Court cases advanced by conservative interests also raised questions about whether facts had been manipulated to get the disputes in front of the court. One of those involved a wedding website designer in Colorado who did not want to work with same-sex couples and a public high school football coach in Washington who wanted to pray on the field.Rosenthal said that “the ugly facts matter” and that the justices could return the Moores' case to a lower court without ruling on it.Charles Moore said in his sworn statement that he agreed to invest in the company that was being formed by his friend and former colleague at Microsoft, Ravindra “Ravi” Kumar Agrawal, because he liked the business plan and trusted his friend.“Moreover, I thought KisanKraft was formed for a noble purpose and had the potential to improve the lives of small and marginal farmers in India,” Moore said. The case had already kicked up ethical questions. Senate Democrats had asked Justice Samuel Alito to step aside from the case because of his interactions with David Rivkin, another lawyer who also is representing the Moores. The Democrats said Alito had cast doubt on his ability to judge the case fairly because he sat for four hours of Wall Street Journal opinion page interviews with an editor at the newspaper and Rivkin.Alito rejected the demands in a four-page statement issued by the court in which he said there “is no valid reason” for his recusal. ___Associated Press writer Fatima Hussein contributed to this report.___This story has been corrected to reflect that Mindy Herzfeld is a professor of tax practice at the University of Florida law school, not director of the master's program in international tax.。    最新消息，来自洛杉矶湖人。         近日，《Lake Show Life》围绕湖人抛出了一连串激进操盘思路，热度直接拉满。         首先来看看库明加。

二 |          作为近期市场上仅剩的热门前锋，湖人和骑士几队都在等待他的下家选择，此前也有多家媒体报道，湖人有机会先签后换完成操作。         但问题在于，库明加是否能解决湖人所有问题呢？          这个问题的答案显然是个问题，而《Lake Show Life》围绕这一点给出的第一笔交易，目标来自以赛亚·斯图尔特。         作为联盟各队都需要的脏活累活型内线，兼具四五号位切换，也具备一定外线投射和出色运动能力；最关键的是，斯图尔特在场并不需要球权。         这一点才是最适配湖人的，作为一支手握东契奇和里夫斯两位持球核心的球队，如果再招募持球前锋，难免出现球权分配问题。         但斯图尔特就不一样了，他的价值在于挡拆吃饼、篮板协防，外线空位也能出手一些三分球；这种角色可能不显眼，但季后赛难免成为决胜关键。

三 |          特别考虑到湖人已经拥有凯斯勒，斯图尔特完全可以作为候补内线，解决第二阵容的护框换防问题，这确实是一个合理搭配。         第二个目标，来自于德里克·琼斯。         理性来看，这笔交易要更有价值得多。         对于目前的湖人，他们最尴尬的就是锋线防守出现断层；小琼斯虽然不是场均高分的球员，但他的价值从来不只在于得分。         上赛季场均出场26.6分钟，基础数据9.9分3.5篮板1.4助攻0.8抢断0.9盖帽，投篮命中率49.6%，三分命中率36.6%。         虽然不算超级球星，但他的优势恰恰是湖人最需要的。特别是东契奇和里夫斯同场时，球队不需要第三个持球大核，自然需要有人查漏补缺。         特别是这种身体天赋出色的球员，在超级巨星身边更是容易打出化学反应；特别从即战力和防守成熟度来看，小琼斯也是一个合适选择。         第三个目标，来自湖人旧将马克斯·克里斯蒂。         对于这笔交易，故事性上比前两笔更有看点。作为湖人自己培养出来的球员，在浓眉交易案中离开湖人，如今又摆上了湖人回购的名单上。         当然，从赛场表现看，现在的克里斯已经今非昔比。         摊开上赛季数据，为独行侠出战77场，基础数据12.3分3.2篮板2助攻，三项命中率44.1%+40.4%+89.9%。

四 |          仅就数据单来看，现在的克里斯蒂已经成长为一名优质3D侧翼，再结合他23岁的年龄，对于湖人确实具备吸引力。         作为球队角色核心，不用每场比赛大量持球，只要做好防守，稳定贡献空位三分，就是适配湖人的目标选项。         所以，最后把选择留给球迷讨论：          如果能够顺利换到库明加，在后续引援计划中，斯图尔特、小琼斯、克里斯蒂三个引援目标，你觉得谁最适配湖人呢？。

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