I rarely get into work on this blog, but in case the average person was to ask me how often the IRS was fair in their audits or the adjustments that they propose, I'd like to point this out as an example:
"The Tax Court held that the IRS's determinations are arbitrary, capricious, and unreasonable. The court further held that T's comparable uncontrolled transaction method, with appropriate adjustments, is the best method to determine the requisite buy-in payment."
So in a nutshell, the IRS made a determination in this case, which goes beyond "we think" and actually means "pay up" and the taxpayer had to go to tax court, where tax court determined the IRS was "arbitrary, capricious, and unreasonable" and the taxpayer's method was "the best method."
This is the mentality that I bring in every time I see an audit or proposed adjustment on a tax return because the IRS really does have a history of getting it completely wrong.
Monday, December 14, 2009
Saturday, December 05, 2009
Winged Migration
I don't usually blog about movies I've seen but the movie Winged Migration had a unique back-story that puts the entire movie in a different perspective.
Winged Migration very much bills itself as an artful documentary, following the migratory paths of many species of birds. It has amazing shots that were taken of the birds in flight that make it seem like the camera wasn't more than inches away from the birds, even as they were flying right along the water or high in the sky. As the credits rolled I noticed a section that I thought was interesting: Animal Trainers. So we were very curious to see how they got these shots and started watching the special feature on the making of the movie. That's where it all got very interesting.
We were fast-forwarding past people talking when we saw someone hand-rearing baby birds. We hit play and they were talking about how baby birds "imprint" their parental figure at a young age. As it continued, we learned that many of the bird groups in the film had been hand-raised from a young age and imprinted with the idea that their human trainers were their parents and taught to be comfortable with the various cameras and equipment being used. As the making of continued we saw the loading and unloading of animals in beautiful settings, saw how so many of the shots we marveled at were arranged for that purpose, and realized that this was not at all the documentary we had thought before seeing this feature.
It doesn't take away from the beauty of the film but it does mar the natural wonder that I initially had from watching it. The movie also tries to make a few ecological points, which I of course agree with but within the context of them being willing to stage shots you also have to question the authenticity of the scenes meant to make you upset at how humans interact with nature.
Winged Migration very much bills itself as an artful documentary, following the migratory paths of many species of birds. It has amazing shots that were taken of the birds in flight that make it seem like the camera wasn't more than inches away from the birds, even as they were flying right along the water or high in the sky. As the credits rolled I noticed a section that I thought was interesting: Animal Trainers. So we were very curious to see how they got these shots and started watching the special feature on the making of the movie. That's where it all got very interesting.
We were fast-forwarding past people talking when we saw someone hand-rearing baby birds. We hit play and they were talking about how baby birds "imprint" their parental figure at a young age. As it continued, we learned that many of the bird groups in the film had been hand-raised from a young age and imprinted with the idea that their human trainers were their parents and taught to be comfortable with the various cameras and equipment being used. As the making of continued we saw the loading and unloading of animals in beautiful settings, saw how so many of the shots we marveled at were arranged for that purpose, and realized that this was not at all the documentary we had thought before seeing this feature.
It doesn't take away from the beauty of the film but it does mar the natural wonder that I initially had from watching it. The movie also tries to make a few ecological points, which I of course agree with but within the context of them being willing to stage shots you also have to question the authenticity of the scenes meant to make you upset at how humans interact with nature.
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