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When your website looks like this:

The Judge is apparently unimpressed by Mr. Prater's "Section 861 argument" that domestic source income is exempt from U.S. taxes. It is, of course, a losing argument; we hope Mr. Prater's clients didn't pay too much of their fees for his advice up front.
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Joe Kristan writes the Tax Update items, and any opinions expressed or implied are not neccesarily shared by anyone else at Roth & Company, P.C. Address questions or comments on Tax Updates to