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URL:  http://boards.fool.com/ltlttodays-weekly-tax-article-raises-two-14367456.aspx

Subject:  Re: Credit where credit is due Date:  2/16/2001  9:39 PM
Author:  TMFTaxes Number:  46621 of 121453

<<Today's weekly tax article raises two concerns for me. First, I believe I should have been credited with the idea. See message no. 15194 on this board: http://boards.fool.com/Message.asp?mid=10824630&sort=postdate , which I posted on May 1, 1999.>>

Hi Bob...

Now that you refreshed my memory, I DO remember having this conversation with you way back then. But it had completely slipped my mind. This point has been raised in a number of articles since then...The Wall Street Journal, The LA Times, and various professional publications to name a few. Not to mention various professional publications that I subscribe to.

So please accept my apologies for not noting that you were the first (again, that's just my unconfirmed recollection) to even bring the point up here in the folders.

<< Second, my ultimate conclusion, reached with the help of Kaye A. Thomas (KATinChicagoLand) of www.fairmark.com (as you'll know if you follow the thread to its end), is that what I describe as the "Shore sale" DOES NOT WORK because of "recognition" rules in the 1999 act. I have not yet seen any analysis discussing why Kaye's conclusion was incorrect, nor have the pertinent statutes changed, as far as I know.>>

Well, if I would have remembered this discussion, I would have also certainly remembered that Kaye disagreed. And I don't often disagree with Kaye...so I would have addressed his points specifically.

You've gotta remember that I'm gettin' older, and 30,000 posts back is a long way. :-)

<<I am troubled about last week's tax article for a similar reason. Once again, as far as I know the key idea (a single person with a 401(k) and an AGI between $95,000 and $100,000 should make a non-deductible traditional IRA contribution and then convert the IRA to a Roth before the end of the calendar year in order to "evade" the income limits on Roth contributions) was published first on the boards by me.>>

Again, I apologize if I stepped on your lines.

<< As an isolated incident, I was willing to give Roy the benefit of the doubt over last week's article; after all, who's to say he didn't have the idea independently and before me? But Roy's reaction to the "Shore sale" thread makes clear that he had not considered the concept, or some of its applications, before reading my post.>>

Again, you are absolutely correct, Bob. But there have been a number of public discussions of this treatment recently. Not to mention various private discussions that I've had with other tax pros. Again, I'm sorry that I didn't give you attribution for having the idea first...way back in early 1999. I simply forgot.

And I STILL don't remember the discussion on the Roth conversion technique (something that has been common knowledge for a little while). Don't get me wrong...I'm not saying that the discussion didn't take place...I just don't remember it.

<< I usually don't do this, but if you agree with me that I should be publicly credited by TMF for the idea, I'll ask that you rec this post. Thank you for your attention.>>

I'll be more than happy to give you attribution on the idea(s) in a method that you'll approve of...either with your "name" or "handle". Just shoot me an e-mail with the wording as you might like to see it, and I'll be more than happy to submit it to my editor.

Again, I wasn't tryiing to steal your thunder. I simply didn't remember the original conversation. So please accept my apologies...and I'll do whatever I can to correct the oversight, and even point folks to the thread so they can read the entire discussion.

Just let me know. And again...my apologies.
TMF Taxes
Roy
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