jerseyhoya wrote:

pacino wrote:

Doll Is Mine wrote:

Katrina Pierson @KatrinaPierson
I can't keep my phone charged due to the mass volume of texts from people all over the country who will #VoteTrump but ⬇️ballot not so much.

Sounds like a faulty battery

Katrina Pierson would never lie to you, pacino

Monkeyboy wrote:So what if Trump said he was going to give up the presidency in favor of Pence if he's elected, or even bows out and gives the spot to Pence. Pence is on the ticket, right? And if Trump can't or won't do it, then Pence would assume the duties, right? I think a lot of people would go to Pence because they want a republican and Trump's people might go along if their fuhrer commanded them.

I'm just trying to find ways he might weasel out of this whole thing. I'm not sure his ego can take a blow like this and he has to be able to read the writing on the wall at this point.

Gimpy wrote:Why was Buffett paying taxes as a minor? What a chump.

shonda rhimes @shondarhimes
I REALLY need him to stop calling me "THE African-Americans" because ARE YOU KIDDING ME?

Alex Seitz-Wald @aseitzwald
Trump was briefed on Russian hacking. "To profess not to know at this point is willful misrepresentation."

Youseff wrote:was thinking it'd be funny if Trump lost, and all these dumbasses who always threaten armed revolution on twitter actually revolt and end up getting slaughtered.

In the 1990s, Trump had three Atlantic City, New Jersey, casinos and an airline, all of which were hemorrhaging money. There was $ 3 billion of debt on these assets, $ 832 million of which was personally guaranteed by him. Lenders forgave the $ 832 million debt in 1995, the year of the disclosed state tax return. That would have produced a huge COD income item, which might have been excluded. Putting together the loan workout with the similar size of the number on the other income line, loan-related loss is a likely explanation.

Why doesn't the COD income appear on the state return? Here's what we assume would have been his structure, because it was a common structure at the time. We assume that he entered the partnerships that owned the casinos using his own S corporation as partner. That S corporation probably was the general partner. An S corporation is a corporation under state law.

As general partner, that S corporation may have been allocated more losses in the form of interest expenses, operating expenses, and depreciation deductions than it could use against the three casinos' insufficient income. Once the income was exhausted, losses could be applied to reduce the owner's basis in the S corporation shares, but it is likely that basis was small. Passthrough of losses is limited to the shareholder's basis in S corporation shares (section 1363(d)).

When the debt was forgiven at the S corporation level, it would have produced a basis bump to Trump as sole shareholder so that unused losses could be used, even if the S corporation qualified for a COD income exclusion because it was insolvent or filed bankruptcy. It probably would have invoked one of those COD income exclusions (section 108(a)(1)(A), (B)). That basis bump would have enabled him to use the resulting loss overhang in perpetuity to offset his income. Essentially, the basis increase allowed the unused NOLs to flow through to the shareholder and avoided attribute reduction because the NOLs were no longer in the corporation.

Gee, shouldn't there have been a suspension of related tax attributes? Not under the law at the time. The Supreme Court held in 2001 that the law literally permitted this apparent double dip result (Gitlitz v. Commissioner, 531 U.S. 206 (2001) (Doc 2001-1085)). Congress reversed the decision in 2002, grandfathering basis bumps incurred before the date of enactment, so Trump would have been grandfathered (section 108(d)(7)).

jerseyhoya wrote:

Doll Is Mine wrote:

Katrina Pierson @KatrinaPierson
I can't keep my phone charged due to the mass volume of texts from people all over the country who will #VoteTrump but ⬇️ballot not so much.