I guess I'll have to tell the partners that some guy on the internet says we've been doing things wrong...
You're still misreading the laws. If you refuse to accept that than we are done. Section 475 are the mark to market rules, not capital gain conversation rules. It applies specifically to dealers of securities (who would otherwise be unable to take deductions for their normal business losses.)
I charge $700/hour. Most of my work now involves cleaning up messes by guys who read one paragraph out of context and got themselves audited when they thought they found a new loophole.
You're still misreading the laws. If you refuse to accept that than we are done. Section 475 are the mark to market rules, not capital gain conversation rules. It applies specifically to dealers of securities (who would otherwise be unable to take deductions for their normal business losses.)
I charge $700/hour. Most of my work now involves cleaning up messes by guys who read one paragraph out of context and got themselves audited when they thought they found a new loophole.