Brian R. Harris’ Post

Well, this is sad news indeed. A couple friends and I were at the Allman Brothers Band's last run of shows at the Fillmore in 2014, and it was an incredible experience. I can't believe it's been ten years already. Although Dickey was no longer with the band at that point, his legacy and music were definitely present and will continue to live on. His unique and instantly recognizable style have been a huge influence to guitarists and in music for more than 50 years. John Timar Stephen Harmon https://lnkd.in/e86jG3j9

The ATF has published a final rule defining who is "engaged in the business" of selling firearms and therefore needs a federal firearms license (FFL). Under the rule, the analysis is whether one is selling predominantly to earn a profit, and as little as one sale can be enough to constitute a business. The tax code contains a similar "for profit" test to distinguish between a business and a hobby. People generally cannot deduct losses from hobbies but they can from businesses. I can't help but wonder about the possibilities for people to now deduct a wide range of firearms expenses because the ATF rule takes an expansive view of what constitutes a firearms business. That is, has the ATF turned many people's hobby into a business? Can a person have a profit motive and be engaged in a firearms business for ATF/FFL purposes but still lack a profit motive and not be in a business for IRS purposes? These are interesting questions, at least for a tax attorney. #taxcontroversy #IRS #taxes #ATF #FFL https://lnkd.in/eqsqUuWa

I'm excited to be back in Miami for the International Tax Conference presented by the Florida Institute of CPAs (FICPA) and the The Florida Bar Tax Section. This is a great opportunity to learn about current developments in tax law and catch up with friends, some of whom I haven't seen since last year's event! #FMHLegal #taxes #taxcontroversy

This is a really interesting update about IRS CI. The fact that its staffing levels are significantly lower than 2010 is not a surprise. That is a consistent trend throughout the IRS. What is most interesting to me is that there were only 655 people sentenced for tax crimes in 2023. If my math is right, that's 13.1 per state, which is way less than I would have imagined for a country with population of more than 330 million people. Either people are extremely diligent about filing their taxes and paying what they owe, or there's a lot more work there than CI's current staffing levels can support. #IRS #taxcontroversy #FMHlegal

I often tell clients and others that the Internal Revenue Service is the only one still communicating by fax. I stand corrected. #taxcontroversy #taxes #FMHLegal https://lnkd.in/gXE6grRd

I'm excited to announce that I was recognized in this year's edition of Best Lawyers in America for Litigation and Controversy - Tax and Tax Law. Congratulations to my partners Micah Fogarty, Matt Mueller and Lauren Taylor who were also recognized. #taxcontroversy #FMHLegal #taxes

I am honored to be recognized along with my partner Micah Fogarty as a Super Lawyer in Tax. Our partner Lauren Taylor was recognized as a Rising Star in Estate Planning & Probate. Congratulations to all our other friends and colleagues throughout the state who were also recognized in this year's edition. #FMHLegal #superlawyers #taxes #taxcontroversy

I had a great time attending the The Florida Bar Tax Section's organizational meeting this past weekend. I'm honored to continued to serve as a co-director of the Federal Tax committee along with Greg McLaughlin of Tripp Scott, P.A.. If there are any tax attorneys in Florida who are not yet part of this great organization, give me a call and we can talk about how to get involved. #taxes #FMHLegal #taxcontroversy

Fogarty Mueller Harris, PLLC is looking for an associate with an interest in tax litigation. More details below. If you are interested or know someone who might be, let me know.