There may be a million things that we haven’t done as a firm. Last month we removed one from the list, when Alterman Law Group and our spouses and partners went out to dinner and then saw Lin-Manuel Miranda’s masterwork “Hamilton” at the Keller Auditorium. The stars in the background are advertising the show. The stars in the front are my colleagues at the firm.
Some Oregon cities tax the income of businesses, but allow partnerships to deduct from their taxable income an allowance for compensation to their partners, whether or not for federal tax purposes the partnership pays the partners a salary. The amount of the deduction is $X per partner and the total deduction depends on the number of partners. If your partnership has twice the partners, it can claim twice the deduction.
Two married couples (let’s call them John and Mary A and Bill and Jane B) formed a partnership some years ago (let’s call it A & B Partnership). A & B Partnership filed city business income tax returns and claimed the compensation deduction based on the partnership having four partners. Last year the city told A & B Partnership that it had only two partners, because it counted Mr. and Mrs. A as one partner (not two) and Mr. and Mrs. B as one partner (not two). The city said that the partnership was entitled to only two compensation deductions, not four, and was assessed for underpaying its city income tax.
The A’s and B’s engaged our office to appeal the tax assessment. We made an unconventional policy argument against the assessment, based on a review of the history of women’s rights in Oregon.
Some arguments require force and bluster. Others can be won with gentle embarrassment. Last month the city agreed with our position and cancelled the assessment. The clients are happy – all four, not two, of them.
Our clients gave us permission to share our letter to the city. In the continuation is a portion of what we wrote. You might enjoy reading it, even if you aren’t a married taxpayer.
I chose this photograph for our firm’s website not just because it’s an accurate if all-too-gray likeness of me, but because of the photograph in the background. It’s of a 1964 political gathering. I included it in my website photograph to acknowledge the two men who most directly influenced the career I chose. They’re both in the background photograph.
Seated at center is my father, an unusually talented and able lawyer, and my first mentor in the profession. (He started teaching me about the business of law and introducing me to his clients before I entered first grade.) I might imagine him looking at me from the photograph with pride, even in black and white.
Left of my father is seated Paul Gold, who besides being my father’s longtime client was also a witness at my parents’ wedding. Mr. Gold was a prominent investor in downtown Portland, and it is he who sparked my interest in the law of real estate.
The man standing at the right was the reason for the gathering: Senator Hubert Humphrey, then running for vice president and famous for being loquacious. The photographer caught him in mid-speech, and he provides another reason I cherish the photograph: it’s one of the few occasions when Dad couldn’t get a word in edgewise.
