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We are saddened to learn of the death of our friend and colleague Ross Smith today. Ross joined our firm in 1993. Our thoughts and prayers are with his family.
Update, 5/17: Services will be Monday, May 20 at New Life Lutheran Church, Norwalk IA, at 11:00 a.m. Visitation will be Sunday at Hamilton on Westown Parkway, West Des Moines, 3:00-7:00 p.m. Complete information here.
So the Worst Acting Commissioner Ever is done. Too bad, they just finished his official portrait.
Somehow I don’t think this ends the scandal.
Confession: I never took seriously complaints that the IRS was harassing Tea Party organizations who filed for tax-exempt status. It didn’t seem impossible, but the IRS can be difficult to anybody, regardless of political affiliation. Don’t be paranoid!
The legacy of the Worst IRS Commissioner Ever gains new luster with this shocking revelation:
In a practice that conservatives complained about during the 2012 election campaign, organizations that used the words “patriots” or “Tea Party” in their tax-exempt status filings were flagged by the IRS for further review.
Lois Lerner, director of the IRS tax-exempt office, said the practice “was absolutely incorrect and it was inappropriate.”
Speaking at an American Bar Association conference in Washington, Lerner said, “We would like to apologize for that.”
Oh, but don’t worry:
Lerner said the screening process was “absolutely not” influenced by anyone in the Obama administration.
All righty, then. Not even the senior administration official who said this about the president of another exempt organization:
“President [Michael] Crowe and the Board of Regents will soon learn all about being audited by the IRS.”
In fact, that was the most senior administration official of all.
The tone of any organization is set at the top. Unwittingly or not, the President’s statement endorsed IRS harassment of his opponents in a Chicago-style wink-nudge kind of way. As it’s safe to assume that IRS employees overwhelmingly voted for the President, a hint might have been all that was needed.
His subordinate IRS Commissioner Doug Shulman wasn’t worried about it. In March 2012 The Worst Commissioner Ever testified:
The Internal Revenue Service is not making it harder for tea party groups to attain tax-exempt status because of their political views, the agency’s chief told Congress on Thursday.
“As you know, we pride ourselves on being a non-political, non-partisan organization,” Shulman said.
Many tea party groups are applying under section 501 (c) (4) of the federal tax code, which grants tax-exempt status as long as organizations are not primarily involved in activity that could influence an election. That determination is up to the IRS.“There’s absolutely no targeting. This is the kind of back and forth that happens to people” who apply for tax-exempt status, Shulman said.
In Washingtonspeak, that’s “inoperative.” Yet whatever “mistakes were made,” they don’t bother the IRS enough to fire anybody, as far as anybody knows. This is an organization that will fire employees for peeking at movie star tax returns. But political harassment — well, mistakes were made.
Worse still, after the initial revelation, the IRS had the nerve to say this:
Mistakes were made initially, but they were in no way due to any political or partisan rationale.
Right. Because “patriot” and “Tea Party” have no political connotations. Exemption applications with those names were beaten to death just by some amazing coincidence.
The next time some poor schmuck is on trial for not reporting income, he should try saying that his underreporting of taxes “was in no way due to any tax avoidance rationale,” just to see how it works.
So I stand corrected. I’ll remember now paranoia about the IRS is perfectly justified. This is a big deal, and it should result in firings. If it’s a firing offence to look at a starlet’s 1040, it should at least be as serious to use the power of the IRS to pick on disfavored political groups.
The TaxProf of course has an excellent roundup. And the right side blog world is all over this:
James Taranto: The New Nixon
Megan McArdle, IRS Singled Out Conservative Groups for Extra Scrutiny
Kevin Williamson, ‘Mistakes Were Made’
Owning a closely-held business through your Individual Retirement Account has always been a high-wire act of tax compliance. The Tax Court snipped one end of the wire for many IRA-owned corporations yesterday.
The biggest danger of owning your business in an IRA has been the risk of having a “prohibited transaction.” The tax law has hair-trigger rules for pension funds and other exempt organizations to prevent abuse of the funds by related parties or trustees.
Prohibited transactions are foot-faults. If you have one, the 15% tax applies to the “amount involved” for each year of the transaction, even if you didn’t mean to do any harm — even if you in fact did no harm. There is no “good-faith” out. Worse, prohibited transactions terminate your IRA, triggering any untaxed income within the account.
In yesterday’s case, a taxpayer acquired a C corporation through an IRA. The taxpayer then guaranteed loans to the corporation. The Tax Court said this constituted an “indirect extension of credit” to the IRA (my emphasis):
As the Commissioner points out, if the statute prohibited only a loan or loan guaranty between a disqualified person and the IRA itself, then the prohibition could be easily and abusively avoided simply by having the IRA create a shell subsidiary to whom the disqualified person could then make a loan. That, however, is an obvious evasion that Congress intended to prevent by using the word “indirect”. The language of section 4975(c)(1)(B), when given its obvious and intended meaning, prohibited Mr. Fleck and Mr. Peek from making loans or loan guaranties either directly to their IRAs or indirectly to their IRAs by way of the entity owned by the IRAs.
That triggered both a prohibited transaction and the termination of the IRA. The corporation was sold in 2006. The termination of the IRA status meant the gain was taxable on the IRA-owner 1040s, rather than sheltered in an IRA. Worse, the court upheld “accuracy-related” penalties.
Have you ever tried to get a loan for a closely-held corporation without personal guarantees? It can be difficult, especially when you have a new business. Unfortunately, owners of startups are often sorely-tempted to use their IRAs as owners, as it may be their best source of equity capital. This case shows how dangerous IRA ownership of your business can be.
I suspect there are a lot of similar taxpayers out there, with much riding on any appeal of this case. The consequences to these folks will be catastrophic, in the same league as the ruin caused by Incentive Stock Options (ISOs) exercised just prior to the dot-com collapse. The ISO disaster was bad enough to get Congress to enact legislative relief. This could also get Congressional attention.
Cite: Peek, 140 T.C. No. 12.
Be careful what you wish for. The WashingtonPost reports: “Senate passes bill letting states tax Internet purchases, siding with traditional retailers“ Congratulations on helping your most fearsome competitor, Main Street.
Megan McArdle explains why Amazon is actually lobbying for the bill. Not only is Amazon big and easily able to afford the added compliance costs, but paying sales tax is a necessary cost of their plan to dominate retail with same-day delivery:
Why the shift?
Because, whatever the history, Amazon’s competitive advantage no longer derives from its tax-free status. Amazon is the cost leader on most products even before you add in sales tax. They’re a marketplace killer because their giant warehouses are vastly more efficient than even a big box store…
Next day and same day delivery will increasingly become the norm, especially in urban areas. But to pull more business from bricks-and-mortar, Amazon warehouses will become a little big more like big box stores: nearer and more numerous.
That’s the tax law in its glory and majesty — giving the same sales tax compliance responsiblities to a nimble, powerful publicly-traded giant and a guy selling stuff out of his basement.
The IRS has issued the 2014 contribution limits for health savings accounts: $3,300 for single plans and $6,550 for family plans. The 2013 limits are $3,250 for single plans and $6,450 for family plans.
You need a “high deductible” plan to qualify to make an HSA contribution. For 2014, that will be a plan with an annual deductible of at least $1,250 for single plans and $2,500 for family coverage; these are identical to the 2013 amounts. The plans can’t have annual out-of-pocket expenses (besides premiums) for 2014 in excess $6,350 for single coverage and $12,700 for family coverage; the 2013 amounts are $6,250 for single coverage and $12,500 for family coverage.
Link: IRS Publication 969 on HSAs.
Paul Neiffer, proprietor of the fine Farm CPA Today blog, stopped in Des Moines today for lunch with me and Roger McEowen of the Iowa State University Center for Agricultural Law and Taxation.
Paul clearly didn’t anticipate the snow we had today when he packed for his visit. After all, it’s 80 degrees today in his hometown of Yakima, Washington. He’s even more fun and interesting in person than he is on his blog.
We were conspiring in advance of the tax school we will be teaching together next month in Traverse City, Michigan (register today!). We hope nobody has to bundle up then.
Going Concern tells us that David Cay Johnston Would Like To See More News Articles About More IRS. He thinks the reduction in IRS funding from the sequester should be treated as a bigger deal.
Fine. It’s important. Let’s expand our discussion and talk about how the IRS is spending the money it already has. For example, it is spending lots of money to go to court to expand its power over tax preparers. It is spending money lobbying Congress to overturn the court decision thwarting its preparer regulation power grab. If it succeeds, it will spend millions imposing busy work requirements on preparers that will cost taxpayers many millions more while lining the pockets of the big franchise tax prep firms.
It is spending money prosecuting a widow who tried to come clean on foreign bank accounts she inherited. It spends money beating up on honest taxpayers who innocently run afoul of obscure foreign account rules.
While it spends money on these things, it sends billions of dollars of your tax money to identity thieves each year. It sends over $10 billion annually to earned income tax credit scammers. It spends very little to help the honest taxpayers whose identities are stolen, and what it spends isn’t very effective.
So yes, let’s talk about IRS spending. And let’s talk about what they should be spending it on. Spending more on not sending money to thieves would be a good start.
Do tax authorities hate the arts? Megan McArdle, in The Taxman Cometh, explains that the tax man is just fine with artists — to a point.
She discuss a sad story in Minnpost.com about a artist couple who have been battling over “hobby loss” issues with the Minnesota Department of Revenue. The story quotes one of the artists:
The tone of all these proceedings have been completely anti-art. There has been an emphasis on creating a product, advertising it for sale, and then selling it. That’s not how it works on the creative end of literature. Writers need to spend a long time writing, getting feedback, moving up the levels of critique, and then they participate in the publishing industry by sending things out to publishers. One tries for the prominent ones first, gets rejected many, many times, and eventually finds a press and an audience.
Ms. McArdle thinks the problem isn’t an aversion to art: it’s that “the couple in question are not actually making any money:”
Business expenses are not supposed to be subsidies for doing something we think is important or valuable. (We do have some of those items in the tax code, too, but Schedule C is not where they normally go.) Business expenses are supposed to be the expenses necessary to generate the profit upon which you pay taxes to the government.
The tax department will disallow your expenses if the auditor deems that 1) the expenses are unnecessary to making a profit or 2) there is no profit.
Close. She’s completely right that business expendutures must be, as the law puts it “ordinary and necessary” for the business. That’s why, for example, an accounting firm might have difficulty deducting expenses for an executive dirigible.
Saying that there is no deduction if “there is no profit” overstates the case. It’s the taxpayer’s “intent” to make money that counts.
Plenty of businesses come and go without ever making a dime, but their expenses may still be deductible. Trouble starts if the losses go on and on, with no obvious prospect for a turnaround — but with continuing prospects for sheltering other taxable income of the business owners. A classic example is the West Des Moines case of a couple who raised Norwegian Forest cats. Over three years the taxpayer claimed less than $3,000 in revenues while deducting over $190,000 in cattery expenses. This offset taxable income from a separate profitable IT consulting business.
The Tax Court judge explained the tax law rules (my emphasis):
Thus, the issues in the final analysis turn upon the question of whether during the years in question the petitioner and the corporation had the requisite intent or motive of making a profit. Intention is a question of fact to be determined not only from the direct testimony as to intent, but a consideration of all the evidence, including the conduct of the parties. The statement of an interested party of his intention and purpose is not necessarily conclusive.
In other words, talk is cheap. It’s what you do that matters. If you continue to adjust your business to find a way to make profits, trim unprofitable lines, keep good records, and follow a reasonable business plan, the tax law cuts you some slack, even with multiple loss years. If at a reasonable point you realize you aren’t going to make money, close the doors, and cut your losses, you probably are fine. But if the losses go on forever with no changes in the business plan, while reducing taxes you would otherwise pay on other income, expect the tax authorities to get upset.
To me the most interesting thing about this article is that, like in Iowa, Minnesota tax officials are raising hobby loss issues on their own. States usually limit themselves to examining state-only issues, like residency. As states become more desparate for revenue, we can expect more of this.
As for supporting the Arts, we staked out our vision of what the tax law can do back in 2005.
Related: IRS.gov, Is Your Hobby a For-Profit Endeavor?
The Obamacare “Net Investment Income” tax hammers trusts. The new 3.8% tax affects trusts with taxable income as low as xxx in 2013. In contrast, it only affects single individuals with Adjusted Gross Income of at least $200,000, and joint filers starting at AGI of $250,000.
“Passive income” is one item subject to the tax. This means most rental income and business income from pass-through entities, unless the trustee “materially participates” in the business.
The new tax piggybacks off of the old “passive loss” rules for determining whether income is passive. If a taxpayer has business income or loss, it is passive unless the taxpayer “materially participates” in an activity. When losses are “passive,” they are only deductible when there is other passive income to offset it, or when the passive business is sold.
So how does a trust participate? A trust can’t punch a time clock, after all. The IRS says in newly-released TAM 201317010 that a trustee’s participation counts as the trust’s participation — and then only if the trustee participates as a trustee.
The TAM involves trusts that own an interest in an S corporation. The trusts each had a main trustee and a “special trustee” who also happened to be president of the S corporation. A corporate president normally has no trouble materially participating in corporate business, but the IRS said that wasn’t good enough (my emphasis):
As Special Trustee, A lacked the power to commit Trust A and Trust B to any course of action or control trust property beyond selling or voting the stock of Company X or Company Y. The work performed by A was as an employee of Company Y and not in A‘s role as a fiduciary of Trust A or Trust B and, therefore, does not count for purposes of determining whether Trust A and Trust B materially participated in the trade or business activities of Company X and Company Y under § 469(h).
I think the IRS is wrong here. They are just making up this requirement that the trustee participate “as a fiduciary.” If somebody is both a trustee and a corporate employee, how are they to divide the time? This IRS requirement should be rejected, but it poses a compliance problem until and unless it is overturned. It creates uncertainty and makes it more difficult for trust businesses to avoid the 3.8% tax.
The TAM also rejects one district court case that allows trustees to count participation of the “employees and agents” as trust participation. I believe the IRS is correct on that point.
More coverage from Peter Reilly: Tough IRS Position Means More Trusts Will Get Hit With New ObamaCare 3.8% Tax. He says “I really have a hard time seeing how you will ever be able to get a trust to be considered to be materially participating in an S
corporation, if this is the logic that is followed.”
A summary of material participation requirements is below the fold.
California CPA Lowell Baisden came east to North Platte, Nebraska, to do tax work for some doctors. It hasn’t gone well, as his current mailing address indicates. Yet he’s still fighting, if not successfully. The Federal Appeals Court for the Eighth Circuit last week rejected an appeal to his 37-month sentence.
Mr. Baisden argued that he suffered from bad legal advice from his attorney, Mr. Vanderslice:
According to Baisden, he had made it clear to Vanderslice that he wanted to plead guilty to a non-tax related crime so that he could keep his CPA license. Baisden also contended that Vanderslice failed to advise him that he would be responsible for a tax loss of more than $1.5 million, an amount that necessitated incarceration. Baisden further argued that he did not feel responsible for the full amount of the tax loss asserted by the government.
If Mr. Baisden didn’t think he might go to prison, he might have bought a copy of the North Platte Bulletin, which reported at the time: “He faces up to five years in prison and $250,000 in fines.”
Mr. Baisden also said that his attorney should have taken his legal advice:
Baisden also stated that he had provided an extensive analysis of his case to Vanderslice and provided tactical advice, which Vanderslice ignored.
Considering what has happened to some folks who took advice from Mr. Baisden, it’s hard to fault Mr. Vanderslice.
The court said that Mr. Baisden had signed off on the plea deal:
Baisden, a CPA, clearly stated during the plea agreement and in open court during a colloquy with the district court that he had thoroughly discussed his case with his counsel, was satisfied with the job his counsel had done, and that no one had made any promises of leniency in exchange for his guilty plea. Furthermore, the plea agreement outlined the charge to which Baisden was pleading, the possible sentence, and was signed by Baisden, his counsel, and the Assistant United States Attorney.
The Moral? If you don’t like the plea deal, there’s not much you can do about it once you sign it. And if a new tax guy comes to town with all sorts of great new tax ideas that no other tax guys in town aren’t willing to go along with, it’s possible that the other guys have their reasons.
Prior coverage: Plea deal on the Platte
Christopher Bergin, Dilemma – The Earned Income Tax Credit (Tax.com). An excellent summary of the problems with the tax law’s biggest welfare program:
Our politicians have tried to do too much through the tax law. And that has created a complicated mess of winners and losers that makes the task of trying to reform it, even to some level of sensible, a daunting one.The poster child for this mess is the Earned Income Tax Credit. Like it or not, the EITC is welfare administered through the tax system. Do we really want our tax system to do that?
The tax law works best if it is seen solely as a tool to finance the government. Much of its hideous complexity comes from using it is the Swiss Army Knife of public policy. As you add more gadgets it becomes less useful at being a knife.
Mr. Bergin isn’t afraid to mention the elephant in the room:
And there is another huge problem. The EITC program leaks like a sieve. More bluntly and honestly stated, well-intentioned as it may be, the EITC has been corrupted. Don’t take my word for it. Recently, the Treasury Inspector General for Tax Administration released a report stating that up to one-quarter of EITC payments made in fiscal 2012 were improper. How much does that represent? Try $13.6 billion. In one year. Using a ten-year budget window, that’s $136 billion, and that’s just the tainted stuff.
Supporters say the EITC is a program that “works.” Can you say that something “works” when it sprays billions to thieves every year?
Read the whole thing.
But the compliance costs imposed by the Marketplace Fairness Act would place smaller upstarts at a distinct disadvantage, which is, I suspect, one reason that market incumbents such as Amazon support the tax. The real cost of taxes is not the revenue out the door to the taxman; it’s the revenue out to the door to the taxman plus all of the costs involved in complying with the tax code.
Peter Reilly, How 38 Studios LLC Turned A CPA Into A Warrior
Paul Neiffer, What About Those 1099s?!
Phil Hodgen, How to Compute Net Tax Liability for Form 8854
Patrick Temple-West, UK’s Cameron fights tax evasion, and more
Howard Gleckman, Will the Retirement of Max Baucus Open the Door to Tax Reform?
And perhaps the short-sightedness and narrow-mindedness is compounded by the “freedom” mentality that has taken such a hold in modern culture
Yes, let’s all get on board with the new hip “docile submission” mentality. Because the government knows best!
David Cay Johnston, Taxpayers Subsidize Rich Anti-Taxers (Tax.com). Speaking up against the ALEC bogeyman.
It’s Friday, you aren’t being productive anyway. Let’s Play a Game of Accountant/Not an Accountant! (Going Concern)
Absolutely stunning and wonderful news out of Florida in a highly-publicized offshore account case. From the Palm Beach Daily News:
U.S. District Judge Kenneth Ryskamp sentenced Mary Estelle Curran of Palm Beach to one year probation Thursday on tax charges, before revoking the sentence five seconds later and sending her out of the courtroom a free woman.
Ryskamp chastised the government for prosecuting the 79-year-old woman when 38,000 other people in the same situation were given immunity.
The woman had inherited Swiss bank accounts from her wealthy husband. Her lawyer had tried to get her into the offshore disclosure program, but the IRS turned her down because her name was on a list provided by Swiss bank UBS. She pleaded guilty to two false return charges. The judge blasted the government for bringing criminal charges:
Based on these facts, did it ever occur to the government to dismiss these charges,” Ryskamp said. “Instead, the government decided it had to make a felon out of this woman?”
That’s been the IRS approach to offshore accounts all along. The IRS has done a terrible job distinguishing the bad guys from inadvertent violators, hitting people who have come forward with accidental violations with ridiculous penalties, rather than welcoming them into compliance — while often letting bigger fish swim away. But the government had no apologies to offer:
Mark Daly, from the Department of Justice Tax Division, told Ryskamp that Curran’s husband, Mortimer, was a “very wealthy man” and shouldn’t have turned to a foreign national for an interpretation of U.S. Law.”
Mortimer is beyond the prosecutors’ reach, so burn the widow! In addition to setting her free, the judge urged her to apply for a presidential pardon, which he promised to endorse.
Bloomberg News, Widow Gets Less Than Minute of Probation in U.S. Tax Case
Janet Novack reports on a study by the leftish advocacy group Citizens for Tax Justice: Stock Options Meant Big Tax Savings For Apple And JPMorgan, As Well As Facebook . The CTJ report calls stock option compensation deductions a “loophole.”
But it’s not. As Ms. Novack points out, “…it’s not like Uncle Sam is getting stiffed. That’s because the executive must report the same amount deducted by the company as ordinary income.” What’s more, the payments result in collection of the 2.9% Medicare tax on taxable compensation — 3.8% starting in 2013. That means total government revenues are actually higher as a result of the options than if the payments were not made.
But the propagandists at CTJ would be delighted to tax both the payor and payee on the same income, as would their Congressional allies, like Michigan Senator Levin.
The stock option “loophole” is actually an evolved response to another stupid populist tax provision: the Section 162(m) $1 million cap on deductible cash compensation for public companies. The cap doesn’t apply to the execs’ option income, so naturally when the market calls for compensation over $1 million, it flows to a vehicle that provides a full deduction.
If they shut the option “loophole” — unlikely — the money will find another one. Yet foolish congresscritters want to expand the $1 million cap to options. Heaven forfend that they undo their old mistake and stop micromanaging executive compensation through the tax law.
The politicians are tripping all over themselves to claim credit for Facebook’s new server farm in Altoona. From The Des Moines Register:
The Iowa Economic Development Authority board today approved $18 million in tax credits for Facebook’s $300 million data center in Altoona.
“Welcome, Facebook,” said board member Pete Brownell. The data center project has been referred to as Siculus Inc. in state documents.
Debi Durham, the state’s economic development director, said she expected that Facebook’s investment would grow to a billion dollars within five or six years.
“It’s good to be friends with Facebook,” she said. Gov. Terry Branstad said Facebook is “about as high-profile a company as it gets.”
The “high profile” bit tells you why politicians love “targeted” tax credits. It gives them an excuse to call a press conference and cut a ribbon, claiming credit for the project like a rooster taking credit for the sunrise. It’s more fun than facing the fact that real economic growth doesn’t come from photo ops. It doesn’t come from paying $580,000 to a wealthy company for each “job” it brings.
Ultimately economic growth comes from making Iowa an attractive place for low-glamor businesses to set up and expand without having to hire lobbyists and tax consultants to tap the corporate welfare keg. It comes from incremental hiring and location decisions that involve no politicians. It calls for discarding high-profile corporate welfare in favor of a simple low-rate system that’s friendly even for obscure businesses — like The Tax Update’s Quick and Dirty Iowa Tax Reform Plan.
To put things into perspective: our firm, Roth & Company, has “created” more jobs, at higher pay rates, than Facebook’s 31 promised jobs. Where’s our $18 million?
A bill is floating around in Congress to have the IRS automatically fill out many tax forms. Robert D. Flach has details, which include a website where you would download a 1040 already filled in; you’d print it and sign it.
A lot of folks hate the idea. I’m sceptical, as I believe the IRS is far from having the data processing abilty to make it work without an enormous error rate. I can imagine the IRS cracking down on taxpayers who claimed and spent erroneously-generated auto refunds, while poor widows would sign off on excessive taxes year after year and then have no recourse after the statute of limitations runs. Robert has this to say:
It would be helpful if a taxpayer, or tax preparer, could access the details of what the IRS has received from payers and payees issuing information returns. But as a reference and not as a pre-prepared return option.
That would actually make sense.
Jason Dinesen asks Are Other Tax Pros Screening EIC Clients?
I’m curious to know if other tax pros are doing any kind of screening of clients and refusing to serve those who qualify for the Earned Income Credit?
And if so, how does that work?
Being on the 14th floor of our building, we don’t get much walk-in business. I see maybe two EIC returns a year — typically a struggling adult offspring of a wealthy parent — just the kind of person who should be receiving welfare benefits, right? But they qualify, assuming they don’t have enough income of their own. So I go through the whole involuntary social worker routine of confirming eligibilty. Meanwhile, as much as 25% of the credits nationwide are improperly claimed anyway — another example of the futility of achieving compliance with a poorly-concieved law by pressuring preparers.
It’s been nice having some time off. It was a tough tax season, and three days away only starts to get me back on track.
Part of the time was spent helping move a relative from an “assisted-living memory unit” at the old-folks home to a “skilled care” unit. Instead of people struggling to come up with money on April 15, you find people struggling to swallow soft food.
Aides and nurses patiently walk people up and down the hallway — taking maybe 15 minutes to go 20 yards. They applaud enthusiastically when somebody hits a balloon back at them with a foam paddle. They bathe them and clean up after their “accidents.” They have to cheerfully stay on task when an Alzheimer’s patient curses them out for doing this. And it has to be done seven days a week, every week.
So it’s back to work for me. I already have a list of projects and a deep pile of emails to deal with. But I am thankful I can deal with them, that my mind hasn’t slipped to where I can’t, and that there are people nicer and more patient than me who are willing to take care of those no longer able to care for themselves.