Monday, October 02, 2006

Awake? Awake.

There was a time when being awake at one in the morning was par for the course, nothing unusual. Frow and I were just getting started on our all-night philosophy jams that would go until four or five. Then I would get up, walk all the way across campus, and fall asleep in Roman History.

But I'm not a freshman any more. I like sleep. I like it a lot. I like my nice firm mattress; I like my comfy blankets; I like (most of all) curling up with Nell*.

Yet I am awake. Sitting on the couch, watching the TVGuide Channel's scroll of late-night crap. Yeah, like I'm going to watch Danny Deutch. Try again CNBC!

The thing is, I barely slept at all last night. I seriously slept for maybe two hours in toto. And that's coming from a guy who enjoys sleep.

When I was in high school, I took a psychology class. One of the few things I remember is that the teacher said that if we couldn't sleep, we should grab a pen and paper and write down our thoughts in a flow-of-consciousness style. I don't think I'm willing to be quite so revealing, but I thought a blog post might be somewhat therapeutic.

But now that I've said that, I can't think of anything to write. And I'm still not tired. Um............... So... Pretty awesome weather today. 1031 transactions turn out to be bigger business than one might expect. My favorite subsection of the Code: 751(b). The longest subsection of the code: 401(a). My least favorite Code subsection: 1(h). Please feel free to submit your own favorite and least favorite section, subsection, or subchapter of the Code. Makes for interesting chitchat.

OK. I think you have all had enough.

*As a side note (I have told one or two people this but I think it bears telling to everyone) when I come home after ten or ten thirty at night due to studying at school and I climb into bed, Nell is inevitably asleep. Despite her unconsciousness, she will role onto her side as soon as I get into bed into to have me spoon with her. I find it quite adorable. If she reads this and finds it too revealing, I may have to take it down, so read it while you can!


Blogger Expatriate Owl said...

I find it difficult to get into an affectionate or disaffectionate relationship with the Internal Revenue Code or any section or subsection thereof. It's just a statutory title!

My "favorite" I.R.C. sections are 6672 and 7502, but the word "favorite" is used in the sense that I have published articles about them, and therefore can claim to be an "expert" regarding them.

Some I.R.C. sections I consider to be "noteworthy" (without playing favorites one way or the other) include, but are not limited to, 102(b) and 102(c), which are exceptions to exceptions to rules.

And because the "rule" now is that he or she who inherits property from a decedent has a stepped-up basis with respect to such property, the regime beginning 1 January 2010, which will eliminate the stepped-up basis, is sort of an exception. And that exception, when it becomes the rule, will have an exception that has an exception. I.R.C. 1022(d)(1)(C)(ii).

Hope that this helps you get to sleep!

-- EO

8:28 AM  
Blogger Xeno said...


Wierded out right now. Thanks for that.

9:43 PM  
Blogger Xeno said...


Wierded out right now. Thanks for that.

9:43 PM  
Blogger Kitty said...

I wish my hubby appreciated it as much as you do when I roll over into the spoon me position. Don't you find the warmth and closeness such a safety zone?

7:01 AM  
Blogger Fishfrog said...

Unfortunately, someone taking up my offer to talk tax does not help me get to sleep, but merely gets me more excited about tax. Also, I have mentioned this to you before, but 1022(d)(1)(C)(ii) will never go into effect. I am willing to enter into a friendly bet with you. Loser admits on his blog that winner has a better handle on a very specifc and minor aspect of tax-politics. Interested?

4:46 PM  
Blogger Expatriate Owl said...

[My prior attempt to post got dropped so I'm reconstructing my comments]

I happen to agree with your supposition that somehow, some way, some time before 1 January 2010 our congresscritters will find a way out of the big mess they have set up by sunsetting the stepped-up basis.

IRC 1022 was a "feel-good" provision that pandered to the redistributionists, but, as surely you can appreciate, putting it into practice ain't going to come off smoothly if they ever try it. For one thing, it imposes upon future decedents (i.e., those now alive) some retroactive requirements to keep records that formerly could have (and in many instances did) go into the Arthur Andersen machine at Enron. But never mind the future decedents; the IRS would have big time problems in auditing, both with the estates of the future decedents and the income tax returns of the living.

11:22 PM  

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