Sunday, November 27, 2011

so much of my Sunday

Researching "Depositions in foreign countries" is what I am doing during this Sunday evening. Every weekend I try to work--research or writing--and rarely successful since by laziness overcomes me and I end up with a few hours of late evening work after many hours of procrastination in front of TV or just doing nothing. Crap.

Wednesday, November 23, 2011

Tax Resolution: taxpayer's right to representation

4.11.55.2.1.2 (04-20-2010)
Request for Representation - Suspension of Interview

  1. Taxpayers have the right to representation at any time during the examination process.

  2. IRC 7521(b)(2) provides that if, during any interview, the taxpayer requests to consult with his/her representative (who is permitted to represent the taxpayer before the IRS), the examiner will immediately suspend the interview regardless of whether the taxpayer may have answered one or more questions.

    Exception:

    An interview will not be suspended if required by a court order or it was initiated via an administrative summons issued under subchapter A of Chapter 78.

  3. Allow the taxpayer a minimum of 10 business days to secure representation before taking any follow-up action to schedule the appointment (extensions can be granted on a case-by-case basis).

    Caution:

    A taxpayer can file a civil suit against the IRS under IRC section 7433 if an IRS employee intentionally or recklessly disregards the provision of the tax code by denying the taxpayer the right to consult with representation or bypassing the representative without proper approval.


Internal Revenue Manual - 4.11.55 Power of Attorney Rights and Responsibilities (Cont. 1)

Sunday, October 09, 2011

Update re: my life

So apparently I did not provide an update of recent changes in my life. I found job... Now I work as a tax attorney in a small law firm. I love my work. Basically, I do the same stuff that I did at the clinic of my LLM program except that things we do at my work are little bit more complicated and clients pay us to do our work (which is, unfortunately, they usually do not do that on time). I think this is the biggest update in my life for the recent months. Telling the truth, I still cannot believe that my dreams came true. Thank you, God!

Friday, September 09, 2011

Working: thoughts of attorneys' value

I think the value of the attorneys is in their creativity that can create something out of nothing, when people of other professions would possibly just give up.

Thursday, July 14, 2011

A pro se plaintif responding to the motion

The clerk advised a pro se defendant on possible consequences if he failed to adequately respond to motion for summary judgment.   The defendant filed a "Petition for Abatement" in which he asserted that the complaint fails to name him as a party on the grounds that his name appears in all upper case letter.

The court's response: "This filing by defendant does not respond in any form to the arguments raised in the Government's motion for summary judgment, and the respondent has failed to otherwise respond to the motion."

United States v. Renfrow, 2009-2 USTC para. 50,580 (E.D.N.C. 2009).

Hey

I have not been here for a while, right.  Actually as always. 

Update is such: three weeks of school left, got part-time job (legal research) but hope that I will be able to find something in tax controversy.  Love tax, and this is the fact.

Summer is passing quickly and I do not feel it is the summer except for the weekends when I sweat at home (from both weather and intensity of studying).

I put sport kind of behind because of time and possibly laziness.  Still do some runs for 30-35 minutes but regretfully no swimming.

That's it.

Saturday, April 02, 2011

Saturday's run

I had my morning run today. It was awesome: rising sun, morning light, empty streets and roads, and a disco music in my headphones.

I think I did not tell before that I used to run for about 8 years almost every morning until I got to a law school and started stressing out and complaining about lack of time.  I quited running but then decided to return and at the first day of my "coming back" I injured my knee.

For more than a year, I envied every runner I saw on a trail or side of a road.  I tried to get back a couple of times, but a sever pain in my knee was stronger than me.  But then overcoming my fear of knee pain, I went to a physical therapist and with help of several exercises and hours of training I returned back to my 35-minutes runs. Unfortunately, one day I tried to run during strong winds and a knee pain returned bringing back my fear of pain and uncertainty that I can run again. 

In last month I have realized that physical exercises mean a lot to me: they bring energy to my body and happiness to my life.  So I have decided that I need get back to my running routine because I feel it is important to me to be able to do it without fear of failure.  

Now I can run only 13 minutes on a trail and about 15 minutes on a tread mill in a gym.  Luckily, I do not have a knee pain, yet <knock on wood>.  But I hope to increase my time to at least 35 minutes. Who knows, maybe one day I will decide to run a marathon :-)))

Friday, April 01, 2011

Today is Friday

A few minutes ago I hang out on FB. Looked at the list of people who is online and then asked myself: who are those people? Seriously, my biggest mistake I made while in a law school was a failure to get more contacts with my classmates. I know faces, but have hard time to place names to those faces. Yeah, I feel bad. Today I spent 6 hours working on my clinic work, even though I planned to spend only 2-3 hours. Sometimes clinic work sucks you into working mood. Finally, I did some cleaning and Santa Claus is gone to a shelf in my closet. I know, it is April, but honestly, I did not have time for a house cleaning.

Thursday, March 31, 2011

The end of March

So I have a beginning of a third quarter. The last quarter was stressful, especially exams. I still have nightmares about me failing. Those dreams are the worst crap I ever had seen in my dreams. Horrible. Surprisingly, I did well in one exam and did very-very well in another. When I checked the results for the first two exams, the grades for the third one were not posted. Today I have learned that they are up. But I am so scared to look at them. It is not that I am afraid to fail. Not at all. I think I did well enough not to get the grade lower than B. But I need A soooo much and I am stressing out about it. Even now, while writing this post I am thinking whether I should go and look. But then I am afraid that if I got B, I will not be able to sleep and my nightmares will be worth than I have now. Hell, no, I am going to wait till tomorrow. ... oh should I??? Imagine, I wrote a last sentence and went to check my grades. O, God, help me!!! ........... ok, checked. Got A but with a low points score. A little upset, since would like to have a better score, since I thought I knew a little bit more than it needed for a solid A, although (being honest) not enough for a high score. rrrrr.... I am going to sleep, hopefully with sweet dreams.

Tuesday, March 08, 2011

Exam

The frustrating part of school is that you may go to the exam with a confidence that you know the most of the material, and that you will do very well. But then you are walking out of that exam with a feeling that much more studying could be done, and that "I know the material" was very deceitful feeling.

This is what I felt yesterday after a Corporate Tax exam. No, I am sure that I did not fail. But, damn, I could do better.

Friday, February 18, 2011

Stressful times

Two days ago while sitting in a school's study room, which I had shared with other two students from my program, I heard their worries about approaching finals.

Being frank with you, till that day I was thinking of exams, but I was not freaking out. But a chain reaction from their talks passed to me quickly, despite my angry resistance.

I have less than two weeks before time when I have to pull out my outlines and spend 3.5 hours writing answers. My two outlines are half-done, one outline looks as a blank page. As always I had planned to catch up on a weekend, and as always I did not. I feel the energy is leaving my body and I have no time to replenish it.

Anyway, I guess my point is I begin worrying and I know it is no good.

Wednesday, February 09, 2011

Inspiration --> motivation --> I am here

I have got an inspiration to start blogging again. Since my life is mostly spent with books and in communication with people who do not care much about events in my life, I have decided to annoy my blog abandoned for so long time with my silly thoughts.

Since a school is a center of my life, I will begin with it. Last quarter ended with good grades (my points received were not excellent, but high enough to get As). This quarter I am taking Estate and Gift tax, International Taxation and Corporate Tax I. International Taxation is most complicated and boring (BTW, this is what I am avoiding to do at this moment but creating this blog entry). I also continue working in a clinic, a time-consuming but interesting stuff.

Beyond-the-school life is boring - TV, shopping, cooking and rare meetings with friends (and by "rare" I mean I did not see them for more than a month). Physical exercises are on my to-do-list but by the end of the day they end up on my things-not-done list. This continues from the beginning of the quarter. It is a pity, because my body looks terrible - fat and ... no, I am not going to talk about gross things.

Now, update is done and I have no excuses for not studying.

By the way, the reason I decided to write is that a February bar exam is approaching, and I see many people with BarBri books in the library and in the school's halls. So what I wanted to say is that I am SO HAPPY that I have passed the bar exam and I am SO GLAD, that rather than studying Con Law or Criminal law or whatever, I need to do my homework for International Taxation. Thank you, God!!!