. At issue were his returns for 2010-2014. He understated income by $2,215,887.06 in total for those five years lowering reported tax by approximately $735,993. The details are in a statement he signed that is available on PACER.The law firm that Miller was with in 2010 was on a fiscal year ending January 31. Since he left the firm in 2010, he received two K-1s for 2010.
Frankly, if Miller had been a dentist or engineer he might have been able to convince someone that it was all a mistake because the full year K-1 would have been labeled 2009. Fiscal year partnerships, particularly for service businesses are pretty unusual.That he was filing the 2010 return over a year late probably didn't help.Miller's 2011 return was prepared in October 2012 around the same time as his 2010 return. He was more brazen on this one.
Back in the day, a technique for freeing up earnings trapped inside a C corporation was for the shareholder to borrow money interest-free. It was a planning technique I learned well. The IRS did not like this one little bit and announced that it would not follow Tax Court decisions that approved it.
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