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piojitos #2164155 11/25/08 11:33 PM
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naughty

My fave...

KiwiJ #2164158 11/25/08 11:46 PM
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rotflmao
(posted on behalf of BigK)

piojitos #2164160 11/25/08 11:51 PM
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Have you ever taken the time to read back over this thread?

It's very scary stuff. :MrEEk: :MrEEk: :MrEEk:

KiwiJ #2164164 11/26/08 12:00 AM
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uhuh

ToddAC #2164167 11/26/08 12:22 AM
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Originally Posted by ToddAC
Here is a small sample of the tax code. This is part of the code that deals with Alernative Minimum Tax.

TITLE 26, Subtitle A, CHAPTER 1, Subchapter A, PART VI, Sec. 59.
STATUTE
(a) Alternative minimum tax foreign tax credit
For purposes of this part -
(1) In general
The alternative minimum tax foreign tax credit for any taxable year shall be the credit which would be determined under section 27(a) for such taxable year if -
(A) the pre-credit tentative minimum tax were the tax against which such credit was taken for purposes of section 904 for the taxable year and all prior taxable years beginning after December 31, 1986,
(B) section 904 were applied on the basis of alternative minimum taxable income instead of taxable income, and
(C) the determination of whether any income is high-taxed income for purposes of section 904(d)(2) were made on the basis of the applicable rate specified in subparagraph (A)(i) or (B)(i) of section 55(b)(1) (whichever applies) in lieu of the highest rate of tax specified in section 1 or 11 (whichever applies).
(2) Limitation to 90 percent of tax
(A) In general
The alternative minimum tax foreign tax credit for any taxable year shall not exceed the excess (if any) of -
(i) the pre-credit tentative minimum tax for the taxable year, over
(ii) 10 percent of the amount which would be the pre-credit tentative minimum tax without regard to the alternative tax net operating loss deduction and section 57(a)(2)(E).
(B) Carryback and carryforward
If the alternative minimum tax foreign tax credit exceeds the amount determined under subparagraph (A), such excess shall, for purposes of this part, be treated as an amount to which section 904(c) applies.
(3) Pre-credit tentative minimum tax
For purposes of this subsection, the term "pre-credit tentative minimum tax" means -
(A) in the case of a taxpayer other than a corporation, the amount determined under the first sentence of section 55(b)(1)(A)(i), or
(B) in the case of a corporation, the amount determined under section 55(b)(1)(B)(i).
(4) Election to use simplified section 904 limitation
(A) In general
In determining the alternative minimum tax foreign tax credit for any taxable year to which an election under this paragraph applies -
(i) subparagraph (B) of paragraph (1) shall not apply, and
(ii) the limitation of section 904 shall be based on the proportion which -
(I) the taxpayer's taxable income (as determined for purposes of the regular tax) from sources without the United States (but not in excess of the taxpayer's entire alternative minimum taxable income), bears to
(II) the taxpayer's entire alternative minimum taxable income for the taxable year.
(B) Election
(i) In general
An election under this paragraph may be made only for the taxpayer's first taxable year which begins after December 31, 1997, and for which the taxpayer claims an alternative minimum tax foreign tax credit.
(ii) Election revocable only with consent
An election under this paragraph, once made, shall apply to the taxable year for which made and all subsequent taxable years unless revoked with the consent of the Secretary.
(b) Minimum tax not to apply to income eligible for credits under
section 30A or 936
In the case of any corporation for which a credit is allowable for the taxable year under section 30A or 936, alternative minimum taxable income shall not include any income with respect to which a credit is determined under section 30A or 936.
(c) Treatment of estates and trusts
In the case of any estate or trust, the alternative minimum taxable income of such estate or trust and any beneficiary thereof shall be determined by applying part I of subchapter J with the adjustments provided in this part.
(d) Apportionment of differently treated items in case of certain
entities
(1) In general
The differently treated items for the taxable year shall be apportioned (in accordance with regulations prescribed by the Secretary) -
(A) Regulated investment companies and real estate investment
trusts
In the case of a regulated investment company to which part I of subchapter M applies or a real estate investment company to which part II of subchapter M applies, between such company or trust and shareholders and holders of beneficial interest in such company or trust.
(B) Common trust funds
In the case of a common trust fund (as defined in section 584(a)), pro rata among the participants of such fund.
(2) Differently treated items
For purposes of this section, the term "differently treated item" means any item of tax preference or any other item which is treated differently for purposes of this part than for purposes of computing the regular tax.
(e) Optional 10-year writeoff of certain tax preferences
(1) In general
For purposes of this title, any qualified expenditure to which an election under this paragraph applies shall be allowed as a deduction ratably over the 10-year period (3-year period in the case of circulation expenditures described in section 173) beginning with the taxable year in which such expenditure was made (or, in the case of a qualified expenditure described in paragraph (2)(C), over the 60-month period beginning with the month in which such expenditure was paid or incurred).
(2) Qualified expenditure
For purposes of this subsection, the term "qualified expenditure" means any amount which, but for an election under this subsection, would have been allowable as a deduction (determined without regard to section 291) for the taxable year in which paid or incurred under -
(A) section 173 (relating to circulation expenditures),
(B) section 174(a) (relating to research and experimental expenditures),
(C) section 263(c) (relating to intangible drilling and development expenditures),
(D) section 616(a) (relating to development expenditures), or
(E) section 617(a) (relating to mining exploration expenditures).
(3) Other sections not applicable
Except as provided in this subsection, no deduction shall be allowed under any other section for any qualified expenditure to which an election under this subsection applies.
(4) Election
(A) In general
An election may be made under paragraph (1) with respect to any portion of any qualified expenditure.
(B) Revocable only with consent
Any election under this subsection may be revoked only with the consent of the Secretary.
(C) Partners and shareholders of S corporations
In the case of a partnership, any election under paragraph (1) shall be made separately by each partner with respect to the partner's allocable share of any qualified expenditure. A similar rule shall apply in the case of an S corporation and its shareholders.
(5) Dispositions
(A) Application of section 1254
In the case of any disposition of property to which section 1254 applies (determined without regard to this section), any deduction under paragraph (1) with respect to amounts which are allocable to such property shall, for purposes of section 1254, be treated as a deduction allowable under section 263(c), 616(a), or 617(a), whichever is appropriate.
(B) Application of section 617(d)
In the case of any disposition of mining property to which section 617(d) applies (determined without regard to this subsection), any deduction under paragraph (1) with respect to amounts which are allocable to such property shall, for purposes of section 617(d), be treated as a deduction allowable under section 617(a).
(6) Amounts to which election apply not treated as tax preference
Any portion of any qualified expenditure to which an election under paragraph (1) applies shall not be treated as an item of tax preference under section 57(a) and section 56 shall not apply to such expenditure.
(f) Coordination with section 291
Except as otherwise provided in this part, section 291 (relating to cutback of corporate preferences) shall apply before the application of this part.
(g) Tax benefit rule
The Secretary may prescribe regulations under which differently treated items shall be properly adjusted where the tax treatment giving rise to such items will not result in the reduction of the taxpayer's regular tax for the taxable year for which the item is taken into account or for any other taxable year.
(h) Coordination with certain limitations
The limitations of sections 704(d), 465, and 1366(d) (and such other provisions as may be specified in regulations) shall be applied for purposes of computing the alternative minimum taxable income of the taxpayer for the taxable year with the adjustments of sections 56, 57, and 58.
(i) Special rule for amounts treated as tax preference
For purposes of this subtitle (other than this part), any amount shall not fail to be treated as wholly exempt from tax imposed by this subtitle solely by reason of being included in alternative minimum taxable income.
(j) Treatment of unearned income of minor children
(1) In general
In the case of a child to whom section 1(g) applies, the exemption amount for purposes of section 55 shall not exceed the sum of -
(A) such child's earned income (as defined in section 911(d)(2)) for the taxable year, plus
(B) $5,000.
(2) Inflation adjustment
In the case of any taxable year beginning in a calendar year after 1998, the dollar amount in paragraph (1)(B) shall be increased by an amount equal to the product of -
(A) such dollar amount, and
(B) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting "1997" for "1992" in subparagraph
(B) thereof. If any increase determined under the preceding sentence is not a multiple of $50, such increase shall be rounded to the nearest multiple of $50.

No I haven't gone back and reread the entire thread for a couple of reasons. First, I'm somewhat afraid to because I don't believe I am quite ready for that. I think there may be too many triggers still. I still hurt even today although not as much. Second, I'm afraid if I read all of ToddAC's poetry that I'll just fall in love all over again and I don't want to suffer withdrawal a second time.

I have quoted one of my favorite ToddAC posts though. This was vintage.

piojitos #2164176 11/26/08 12:44 AM
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KiwiJ,

One of my biggest regrets is that I made larousse mad. You had no small hand in that BTW. But I still regret it.

Remember the crazy Mexican serial cheater woman who took such a personal interest in attacking me and tried to get me divorced?

I was looking back to November 2006 and I saw one of my posts where I really got hammered by Justuss. I wonder what it was that I said. I can't remember now.

piojitos #2164179 11/26/08 12:50 AM
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How about when you nicnamed Mel "Cruella De Lane".

TEEF < -- Me, in trouble now

Resilient #2164182 11/26/08 12:53 AM
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Okay that merited the big 8 0 0 0.

I think I'm the one in trouble now though. shocked

piojitos #2164183 11/26/08 12:55 AM
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Pack your bags and brace yourself, we're going on a ML trip.

<ducks>

Resilient #2164184 11/26/08 12:57 AM
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Or better yet, gurd your loins. LOL

<I'm crackin myself up> smirk

Resilient #2164185 11/26/08 12:59 AM
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I always wondered how to spell "gurd". Not a word I get to use a lot.

piojitos #2164188 11/26/08 01:29 AM
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Gird your loins. Guard your lions. Don't get them confused.:MrEEk:

thndrnltng #2164189 11/26/08 01:32 AM
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What would I confuse my loins with?

piojitos #2164190 11/26/08 01:34 AM
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Oh and please keep posting to move Resilient's 8000th post off the last page. Who knows when ML will wake up and I want it gone by then.

piojitos #2164194 11/26/08 01:46 AM
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Well, I guess a guy might want to both guard AND gird his loins. But I'm thinking lion girding might be a touch dangerous. He might decided to guard his OWN loins from your girding attempts, and then you'd be in a whole HEAP o' TROUBLE... uhuh

thndrnltng #2164197 11/26/08 02:01 AM
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Sheesh, THIS isn't the "groping" thread.

I had NO part in making Larousse mad. She loved me.

Seriously, or not as the case may be, we were like a big bickering family. I've been reading back. Geez, we were funny. Yeah, it all turned to custard at one stage (do you use that expression in the States) but I hope we're past that now.

What about the "poster" who thought you (Pio) hung the moon. Talk about embarrassing. faint Sheesh, it wasn't me if any newer posters are reading this.

Yeah, Todd. I know your EA was going to turn PA. That's how these things work out though.

Last edited by KiwiJ; 11/26/08 02:04 AM.
KiwiJ #2164198 11/26/08 02:09 AM
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I know larousse loved you - that's why she got mad - because Todd and I kicked you around so badly.

No I don't remember the poster that thought I hung the moon? Which one was it?

I do remember the guy who decided to get divorced and was chasing an skirt that walked in front of him.

I remember the pistol-packin 2much.

I remember nams.

I remember luna.

I remember cc(whatever the suffix is this week).

I remember stph [sic?].

I do remember a lot of posters that thought TODD hung the moon.

I just hung around him because he was a "babe magnet".

piojitos #2164200 11/26/08 02:13 AM
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lol, yeah, the "Todd groupies".

FraidyCat (that was probably one of many names) thought you were intelligent rotflmao and thought you "hung the moon" rotflmao

2much was cool - a lovely lady. So was Nams. And Luna. Good grief, Steph, I wonder what happened to her. Booka, I think was the divorced guy. He's still around.

KiwiJ #2164207 11/26/08 02:44 AM
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You would never, EVER want to mistake "girding" for "groping," at least not if you're dealing with a lion. With a loin it might work out OK under certain circumstances, but the girded lion might give his girder a girled loin... :MrEEk:

Resilient #2164210 11/26/08 02:51 AM
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Originally Posted by Resilient
How about when you nicnamed Mel "Cruella De Lane".

TEEF < -- Me, in trouble now


that little foreign fiend called me what??? grumble


"It is not the critic who counts; not the man who points out how the strong man stumbles, or where the doer of deeds could have done them better. The credit belongs to the man who is actually in the arena.." Theodore Roosevelt

Exposure 101


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