IMA Tax Update
January 7, 2016
Joe Kristan
Roth & Company, P.C.
www.taxupdateblog.com
Twitter: @joebwan
Also on Facebook!
PL 113-113
Protecting Americans From Tax
Hikes Act of 2015
“PATH”
PATH
•
Makes some of the perpetually-expiring provisions
permanent
•
Makes some provisions safe thorough 2019
•
Extends the rest for two years
•
All extensions retroactive to beginning of 2015
Key Permanent Business Extenders
•
$500,000 Section 179 limit
•
Research Credit
•
5-year S corporation built-in gain “recognition period.”
•
Gain exclusion for 5-year original issue C corp shares
•
15-year depreciation for certain building costs
•
Contributions of food held as inventory
•
S corporation basis adjustments- property gifts
•
Work Opportunity Credit for veterans
Key Permanent Individual Breaks
•
IRA charitable distributions
•
Alternative deduction for state & local sales tax
•
Conservation easement deductions
•
Enhanced child credit
•
Enhanced earned income credit
•
Teacher expenses
•
Mass transit and parking benefits
•
Optional alternative sales tax deduction
•
American Opportunity Tax Credit
Extended through 2019
• Bonus Depreciation
• New Markets Tax Credit
• Work Opportunity Tax Credit
The Two-Year Extenders
• Exclusion for mortgage debt forgiveness
• Credit for “2-wheeled plug-in electric vehicles
• Biodiesel & renewable diesel incentives
• Energy efficient new home credit
• Work Opportunity Tax Credit
• A bunch of others
Permanent Sec. 179
•Sec. 179 limit $500,000 for 2015
•Phases out as qualifying property placed in service
exceeds $2 million
•Limits adjusted for inflation starting in 2016
•Ability to retroactively revoke or elect 179
permanently extended
5-year S Corporation Built-in Gain
“Recognition Period”
• 35% “Built-in Gains” tax applies to income
accrued as a C corporation but recognized
during the “recognition period” following an S
corporation election.
• Recognition period originally enacted as a 10year period in 1986.
Gain Exclusion for 5-year
Original Issue C Corp Shares
• Exclusion applies to gain on shares of “qualified
small business stock held for five years by noncorporate owners.
• C corporation shares acquired in original issue
after 9/27/2010
• Corporation must meet size limits
• Excludible gain limited to $10 million lifetime or
$10x basis.
15-year Life for Certain Buildings
Qualified Leasehold Improvements: made
pursuant to a lease more than 3 years after
building placed in service
Can’t be a related-party lease
Must be interior space; can’t be enlargement,
elevator, escalator, or structural component.
15-year Life for Certain Buildings
Qualified Retail Property: Improvements of
a building portion that is open to the general
public and is used in the retail trade or business
of selling tangible personal property to the
general public, and placed in service more than
three years after the date the building was first
placed in service.
Similar limitations to qualified leasehold
property
15-year Life for Certain Buildings
Qualified Restaurant Property: a building or
building improvement if more than 50% of
square footage is for prep and seating for
on-premises meals.
Charitable Contributions by IRAs
IRAs may contribute up to $100,000 annually to
charities (other than private foundations) if the IRA
owner is 70 ½.
These can be made to satisfy RMD requirements
Why are IRA contributions better?
Child Credit made Permanent
“Enhanced” $1,000 per-child refundable
credit made permanent. Refundable to
extent of greater of:
15% of the amount of earned income over $3,000
or
If taxpayer has 3 or more qualifying children,
excess of Social Security tax over EIC for the year
Earned Income Credit Changes
• 45% rate for taxpayers with three or
more qualifying children made
permanent
• Reduction in earned income credit
marriage penalty made permanent
Bonus Depreciation
• 50% rate extended retroactively from 1/1/15
through 2017
• 40% bonus for property placed in service in
calendar year 2018
• 30% for property placed in service in calendar
year 2019
Bonus Depreciation
• All interior improvements to buildings other
than structural work, enlargement, and
elevators and escalators will be eligible for
bonus depreciation, starting in 2016.
• Available for improvements eligible for 15-year
lives.
Bonus Depreciation
• First-year Sec. 280F cap for autos is increased by
$8,000 for bonus-eligible vehicles (to $11,160
for 2015)
• $8,000 amount reduced to $6,400 in 2018 and
$4,800 for 2019
Research Credit Modifications
• Credits generated by businesses with gross
receipts under $50 million can offset AMT, for
credits generated after 2015
• Qualified small businesses (gross receipts under
$5 million) can offset payroll taxes with research
credits after 2015
Work Opportunity Credit Modifications
Extended through 2019
Expended to cover “qualified long-term
unemployment recipient”
• Certified by job service as being unemployed at least
27 weeks
• New class applies starting in 2016
College Spiffs
•
American Opportunity Credit made permanent (100% of
qualified tuition and related expenses up to $2,500; up
to $1,000 refundable
•
Above-the-line qualified tuition deduction extended
through 2016
•
$250 teacher expense deduction made permanent,
expanded, indexed
•
Computer equipment, software qualify for Sec. 529
plans retroactive for 2015
Items Extended through 2016 Include
•Nonbusiness energy property credit
•New energy-efficient home credit for contractors
•Biodiesel and renewable diesel credits
Other
• FIRPTA withholding rate increased to 15% (from
10%) starting 2/17/16
• “Cadillac Tax” deferred to 2020
• Renewable credit for qualified wind facilities
2016 Iowa Issues
Sales Tax on Manufacturing Supplies
Effective July 1, 2016…
Broader exemption for “consumable
manufacturing supplies” (machinery and
equipment used in the manufacturing
process)
Implications of Comptroller v. Wynne
Facts:
• Maryland statutes imposing a tax on income Maryland residents
earned outside Maryland violated the dormant Commerce Clause
• Must offer Maryland residents a full credit against the income
taxes paid to other states
IDOR announcement:
• Will discontinue practice of allowing the out-of-state tax credit to
apply only to state income tax liability rather than also to local tax
(surtax) liability
• Impacted taxpayers can amend their returns to claim a refund for
tax years 2012-2014
• New forms for 2015 will reflect the Court’s ruling
Short-Term Home Rentals
IDOR Policy Letter No. 15510049 (Oct. 21, 2015)
Short-term home rentals are subject to
Iowa’s 5% hotel/motel tax
Other changes this year
New Audit Rules
• The partnership would be permitted to issue
adjusted Schedules K-1 to the partners of the
reviewed year.
• The recomputed tax for the reviewed year
would be paid in the adjustment year. If so, the
partners would take the adjustment into
account on their individual returns in the
adjustment year (not the reviewed year).
• I.R.C. §6226(b)(1).
New Audit Rules
• In addition, rather than amending the
partnership tax return, partnerships will
have the option of initiating an
adjustment for a reviewed year.
• The adjustment could be taken into
account at the partnership level or the
partnership could issue adjusted
information return to each partner of the
reviewed year.
Individual Mandate Penalty Up
For 2015, it’s the greater of …
• $325/adult, plus $162.50/child under age 18
with a maximum of $975
or
• 2% of household income above the tax filing
threshold
Large employer ACA reporting
• All employers that are applicable large
employers are subject to the Employer Shared
Responsibility provisions, including for-profit,
non-profit, and government entity employers
• Employer’s with fewer than 50 employees are
not mandated to provide insurance, but may
still must comply with the information reporting
requirements.
Two Provisions
Two provisions of the Affordable Care Act apply to
applicable large employers (ALEs):
• The employer shared responsibility provisions;
and
• The employer information reporting provisions for
offers of minimum essential coverage and
minimum value
In addition, self-insured ALEs – that is, employers who
sponsor self-insured group health plans – have
additional provider information reporting requirements
Applicable Large Employer
New forms that ALEs will use to complete this reporting
• Form 1095-C, Employer-Provided Health Insurance
Offer and Coverage
• Form 1095-C is used to report information about each fulltime employee, and is the form that is furnished to full-time
employees
• Form 1094-C, Transmittal of Employer-Provided Health
Insurance Offer and Coverage Information Returns
• Form 1094-C is used to report to the IRS summary information
and to transmit Forms 1095-C to the IRS
Applicable Large Employer
ALE Status is determined on a
controlled group basis!
Applicable Large Employer
Notice 2016-4 Extends Deadlines for
1095-B and 1095-C reporting.
Employer Health Reimbursement Plans
Health Reimbursement Arrangements (HRAs):
Authorized by §§105, 106, HRAs are employerfunded plans used to reimburse (tax-free)
employee medical expenses, including health
insurance premiums.
Medical Expense Reimbursement Plans (MERPS):
Also allowed under §105, MERPs reimburse
employee medical expenses, but unused amounts
are not carried over to following years.
Other Employer Reimbursement Plans
• Healthcare Flexible Spending Accounts (FSAs)
(§125): Employers and employees (limited to
$2,550) may contribute pre-tax dollars to this
plan through cafeteria plan, which will
reimburse employee for medical expenses.
• Employer Payment Plans (§106): Employers
reimburse employees for substantiated
premiums, and payments are excluded from
income.
IRS Notice 2013-54 Market “Reforms”
• Employer health reimbursement plans are
generally considered group health plans.
Group health plan is defined as “a plan of, or contributed to by,
…an employer…to provide health care (directly or otherwise) to
the employees or their families.” IRC §5000(b)(1)
• Group health plans (unless exempt) are subject
to ACA market reforms, in particular:
• No annual dollar limits on essential health benefits.
• No cost-sharing for preventive health services
IRS Notice 2013-54
Bottom Line:
Because most standalone (not integrated with another
group plan) employer health reimbursement plans impose
limits on what they reimburse and because they do not
ensure preventive services at no cost, they violate the
market reforms (if not exempt).
Offering such plans subjects employers to stiff penalties (up
to $100 per day per violation per employee ($36,500/year).
Excepted from Market Reforms
•
The following types of reimbursement plans are
specifically excepted from ACA market reforms and are
therefore still allowed:
• Plans with fewer than two persons who are current
employees.
• Plans that provide only excepted benefits, including:
• Accident-only coverage
• Disability income
• Certain Long-term care
• Certain limited scope dental and vision benefits
• Employee Assistance Program benefits
HRA Integration
Beginning January 1, 2014, an HRA must
provide only excepted benefits or be
integrated with an ACA-compliant employer
sponsored group health plan.
HRA’s may not be integrated with a plan
purchased on the Marketplace. They may,
however, be integrated with an employer
group plan purchased via SHOP.
New Guidance on
Reimbursement Arrangements
DOL ACA FAQ XXII, Q&A3
“A vendor markets a product to employers claiming that
employers can cancel their group policies, set up a Code
section 105 reimbursement plan that works with health
insurance brokers or agents to help employees select
individual insurance policies, and allow eligible employees
to access the premium tax credits for Marketplace
coverage. Is this permissible?
“No. The Departments have been informed that some
vendors are marketing such products. However, these
arrangements are problematic for several reasons.”
What About 2% Shareholders?
• Can you reimburse S corp. 2 percent
shareholder-employees’ individual premiums or
is that also subject to the market reforms?
• No excise tax through 2015 (so, no Form 8928)
• But, no application to reimbursement for non- 2%
shareholders
• Transitional relief through June 30, 2015 applies
• Rely on Notice 2008-1 until further guidance
issued
Self-Rental Rule
 Rented for use in trade or business in
which the taxpayer materially
participates, and
 Is not property rented incidental to a
development activity
Identity Theft
ID theft tips
•
•
•
•
•
•
Social security cards and other documents with a social security
number (SSN) or individual taxpayer identification number (ITIN)
should not be carried in the taxpayer’s wallet or purse
An SSN or ITIN should not be provided to a business or other party
unless absolutely necessary
Confidential financial and other personal information should be
protected and access to this information should be limited by using
physical locks, computer passwords, or other security measures
Credit reports should be reviewed annually
Personal computers should be protected using firewalls, anti-spam
and anti-virus software, updated security patches, and passwords
for online accounts should be regularly changed
Personal information should only be provided by phone, fax, or
Internet if it is given to a known party
Publication 4557
"Safeguarding Taxpayer Data - A Guide for Your Business"
• "Safeguarding Taxpayer Data - A Guide for Your
Business"
• The purpose of this publication is to provide
information on legal requirements to safeguard
taxpayer data
• Safeguarding taxpayer data is a top priority
• It is the legal responsibility of government,
businesses, organizations and individuals that
receive, maintain, share, transmit or store
taxpayers’ personal information
Signs of Identity Theft
•
•
The taxpayer discovers that more than one tax return for
them was filed with the IRS
The taxpayer discovers there is :
• A balance due
• Refund offset, or
• Collection action taken against them for a year for which they did
not file a tax return
•
IRS records indicate the taxpayer received more wages than
actually received
•
The taxpayer’s state or federal benefits were reduced or
canceled because the agency received information about an
income change
Foreign reporting issues
Foreign Bank Account Reporting
United States persons are required to report under
FBAR rules if:
1. the United States person had a financial interest in or
signature authority over at least one financial
account located outside of the United States; and
2. the aggregate value of all foreign financial accounts
exceeded $10,000 at any time during the calendar
year reported.
Reportable Account
• Bank accounts
• Securities and Commodities Accounts
• Mutual funds
• Cash value insurance and annuity policies
Reportable Account
Foreign insurers with U.S. policies include
(among others), Sun Life and Foresters.
The 2013 ACLI fact book lists 99 foreign life
companies operating in the U.S. in 2012.
Reportable Account
• Retirement accounts, including Canadian
Registered Retirement Savings Plans,
Canadian Tax-free Savings Accounts, and
Mexican AFORE accounts.
• Offshore gambling accounts
Reportable Account
• Directly-held shares in foreign companies,
ownership of foreign partnerships, U.S.
mutual funds holding foreign stocks, and
deposits in U.S. branches of foreign banks
are not foreign financial accounts.
• Note: other reporting requirements may
apply to interest in foreign financial
assets.
Form 8938, Foreign Financial Assets
• “Specified persons” must report
interests in “Specified foreign
financial assets” that exceed the
thresholds specified by law.
Form 8938, Foreign Financial Assets
Foreign Financial Asset
• Stock or security issued by non-U.S.
person
• Interest in a foreign entity
• A financial instrument with a nonU.S. issuer or counterparty
Form 8938, Foreign Financial Assets
Unmarried taxpayers and married taxpayers
filing separately:
Total value of specified foreign financial
assets exceeds $50,000 on the last day of the
tax year or $75,000 at any time during the
tax year. These thresholds are $200,000 and
$300,000 for taxpayers living abroad.
Form 8938, Foreign Financial Assets
• Married taxpayers filing a joint
income tax return: Total value of
specified foreign financial assets
exceeds $100,000 on the last day of
the tax year or $150,000 at any time
during the tax year. These thresholds
are $400,000 and $600,000 for
taxpayers living abroad.
Form 8938, Foreign Financial Assets
• Form 8938 is filed with Form 1040. Unlike
the FBAR, it is part of the 1040, and it is
not required for 1041s or other entity
returns.
Form 3520: Foreign Gifts and Trusts
• Gifts and bequests received from
outside the U.S. are tax-free, like U.S.
gifts, but unlike with U.S. gifts, there
is a reporting requirement for the
U.S. recipient.
Form 3520-A: Foreign Grantor Trusts
Annual return for foreign grantor trusts
Calendar-year filing due March 15.
•
Filed by “Each U.S. person treated as an owner
of the Foreign Trust.”
• Non-filer penalties: Greater of $10,000 or 5% of
the value of trust assets treated as owned by
the U.S. person.
Form 5471
• Information Return of U.S. Persons With
Respect To Certain Foreign Corporations This
applies to U.S. taxpayers who own 10% or more
of the stock of a foreign corporation, or to U.S.
officer or director of a corporation in which a
U.S. person owns a 10% interest. Related party
rules apply in determining the 10% thresholds.
Form 5472
Information Return of a 25% ForeignOwned U.S. Corporation or a Foreign
Corporation Engaged in a U.S. Trade or
Business
Attribution rules apply.
Form 8865
Return of U.S. Persons With Respect to
Certain Foreign Partnerships
• Similar to Form 5471 for owners of
10%+ interests in foreign
partnerships.
Form 8858
Form 8858, Information return of U.S.
Persons With Respect to Foreign
Disregarded Entities
• This is filed for directly-owned foreign
disregarded entities and those owned by
controlled foreign corporations for which
there is a Form 5471 filing requirement.
Form 1042
Annual Withholding Tax Return for U.S.
Source Income of Foreign Persons
•
Required for interest, dividends, rents, other
“Fixed or determinable annual or periodic
income.”
•
Deposit dates similar to a payroll tax schedule,
based on withheld amounts.
Form 8804
Annual Return for Partnership
Withholding Tax (Section 1446)
•
•
Required for partnerships with non-U.S.
partners.
Remittances similar to estimated tax
schedule
Form 8288
U.S. Withholding Tax Return for
Dispositions by Foreign Persons of U.S.
Real Property Interests.
• Remittance required from buyer within 20 days
of close of purchase from non-U.S. person.
Interesting 2015 cases
Vanney Associates Inc. v. Comm’r
 Vanney Associates, Inc.
Personal service corporation
Cash basis
Bonus Check Deduction
 Robert Vanney
Architect for 39 years
Sole shareholder of Vanney Assoc.
CEO, CFO, VP of Marketing, VP of
Operations, Dir. of HR
 Karen Vanney
CPA
Works elsewhere
Does Vanney Assoc. payroll
Bonus Check Deduction
 2008 Robert received $240,000 wages and
$815,000 year-end bonus
 Practice was to calculate company profits and
pay to Robert as a yearend bonus
 Net check to Robert was $464,183
 Endorsed bonus check and signed back over
to Vanney Assoc.
 Recorded as a loan that was repaid March
2009
Bonus Check Deduction
 12/31/2008
 Vanney Assoc. bank balance $283,033
 2008 corporate return
 $1.055 million claimed as officer compensation
 $123,191 taxes and licenses
$11,818 of that was Medicare taxes
 IRS disallowed $815,000 of officer
compensation and $11,818 for taxes and
licenses
Issue
• Whether Vanney Assoc. can deduct
officer compensation and taxes
related to the year-end bonus
Analysis
 Vanney claimed restricted use of the check
 He could NOT
Cash it
Use it to pay a debt
Use it to make a loan to anyone else
 His only option was to lend it back to Vanney
Assoc.
Holding
• No deduction for officer compensation
allowed
William (Dave) and Caroline Evans
v. Comm’r
 Dave owns Dave Evans Construction, LLC (DEC)
 General contractor in Boise licensed only in ID
“Boise is a major center for motocross racing”
“A local race can easily attract 1,000 riders.”
DEC Gross Revenues
Promotional Expense Deduction
 The Evans have 5 children, all race motocross
 Evans paid for all motocross expenses
 Son Ben’s racing career took off in 2005
 CPA advised supporting Ben’s racing could be
a valid promotional activity
DEC became a sponsor
 2007, Ben won the premier title to move to
the pro circuit
Promotional Expense Deduction
Motocross-racing-related income & expenses
DEC’s other advertising expense
DEC stopped paying Ben’s racing-related expenses after he
started pro circuit in 2007
Issues
 Whether racing activity expenses were
ordinary and necessary business expenses
 Whether racing activity expenses were
reasonable
 Whether they can take §179 deduction for
the motorhome
Analysis
 DEC sponsorship…”boosted exposure and
goodwill within the community.”
 Expenses were ordinary and necessary
 “…in light of the significant tangible and
intangible benefits DEC obtained…”
Amounts spent were reasonable
 Okay to take §179 on motorhome
Used primarily to transport Ben and his
motorcycles
Splitting IRA Proceeds With Siblings
Doesn’t Avoid Tax
•
Morris v. Comr., T.C. Memo. 2015-82
• Facts:
• Taxpayer was adult son that was the sole beneficiary listed on his father’s IRA
which had a balance of $96,422 at the time of the father’s death
• Taxpayer took a lump-sum distribution which was reported to him on From
1099-R (in addition to the annual distribution that had previously been made
to his father before death)
• Taxpayer believed his father would have been to share the IRA with his two
siblings, so he sent them $37,000 total
• Taxpayer didn’t report any of the distribution as income based on advice from
the law firm probating the estate
• Paralegal said there would be no tax due on the IRA
• She meant no federal estate tax due or state death taxes
• He understood her to mean there would be no income tax to him
• IRS sends SNOD for $27,037 (including the penalty which was later dropped)
• Court agrees with IRS – voluntarily sharing the proceeds does not eliminated
the tax liability
Contract Payments For (Human) Egg
Production Not Excludible
•
Perez v. Comr., 144 T.C. No. 4 (2015)
• Facts:
• Taxpayer entered into contracts to produce unfertilized eggs for
transfer to infertile couples
• Contracts characterized payments as being form petitioner’s time,
effort inconvenience, pain and suffering and not in exchange for or
purchase of eggs
• Taxpayer underwent numerous physical exams and self-administered
painful hormonal injections, suffering bruisings and surgery to
harvest the eggs
• Taxpayer received $20,000 under the contracts and received a Form
1099, but didn’t report any of it
• Excluded it under I.R.C. §104(a)(2) as damage payments for pain and
suffering
• IRS said “no”
Contract Payments For (Human) Egg
Production Not Excludible
•
The court’s analysis…
• The payments were received for personal services
rendered and are not excluded under I.R.C. §104
• The fact that the petitioner suffered physical pain
or injury during the performance of rendering
services pursuant to the contract did not change
that result
• The payment was not received on account of
personal injuries or sickness, but rather for services
• Court noted that the taxpayer voluntarily
contracted to be paid to produce eggs via a process
that involved pain and suffering
Like-Kind Exchanges
•
There is a 2-year holding period requirement in related
party exchanges
• An exception applies if the IRS is satisfied that neither the
exchange nor the disposition has as one of its principal purposes
the avoidance of federal income tax. I.R.C. §103(f)(2)(C)
• Taxpayer bears the burden of proof
• Note: If the principal purpose is to avoid state income tax, it
might qualify. This could allow for an exchange of low basis
property between a parent residing in a high-tax state and a
child residing in a state without an income tax.
North Central Leasing (8th Cir. 2015)
•
Facts:
• Plaintiff was a subsidiary of a Caterpillar dealer that sold
Caterpillar equipment, and ran the dealer’s rental and
leasing operations.
• Plaintiff sold used equipment to third parties who then paid
the sales proceeds to a q.i.
• The q.i. forwarded the sales proceeds to the dealer who
then bought new Caterpillar equipment for the plaintiff and
then transferred the new equipment to the petitioner
through the q.i.
• Arrangement provided favorable financing from Caterpillar
and the dealer had up to 6 months from invoice date to pay
Caterpillar for the petitioner’s new equipment
North Central Leasing (8th Cir. 2015)
•
Outcome:
• Not a tax-deferred exchange
• Resulted in basis-shifting
• Resulted in related party’s receiving cash that was
unfettered and unrestrained for 6 months
• Resulted in a significant reduction in taxes for the
related party
• Taxpayer couldn’t explain the reason for the related
party’s involvement in the exchanges or the unneeded
complexity of the transactions
• 8th Circuit agreed with the 11th Cir. (Ocmulgee Fields) and 9th
Cir. in Teruya Bros
Richard S. Leyh and Ellen O’Neill
Rental real estate professional
requirements:
• More than 750 hours in real estate
business activities
• More real estate hours than all
other activities.
Richard S. Leyh and Ellen O’Neill
“Petitioner provided day-by-day
explanations of the specific rental real estate
activity in her log. Further, from the log it
was easy to identify days when the activity
took place in Austin. Finally, petitioner has
shown that the travel time was not included
in the original log. Petitioner's log and her
revised log showing the travel time are well
within the guidelines…”
Robert and Pamela Redisch
Taxpayers stopped using Florida condo and
offered it for rent. They never rented it.
They then sold it for a substantial loss.
“After considering all of the facts and
circumstances, we find that the Porto Mar
property was not converted to a rental
property. “
The Ellis Case
(8th Cir. 2015)
Facts:
• The taxpayer was the fiduciary of his IRA, entered into prohibited transactions
under both I.R.C. § 4975(c)(1)(D) (see item (4), and I.R.C. §4975(c)(1)(E).
• The taxpayer had directed his IRA to purchase a 98% membership interest in a
limited liability company (“LLC”) that he had created, and then received
compensation from the LLC for services performed for the LLC.
• As the IRA's fiduciary and beneficial shareholder of more than 50% of outstanding
ownership interest in LLC, the taxpayer thus engaged in the indirect transfer of
plan income or assets for his own benefit, in violation of I.R.C. §4975(c)(1)(D).
• Plus, in authorizing and effecting the transfer, the taxpayer had dealt with IRA
income or assets for his own account, as prohibited by I.R.C. §4975(c)(1)(E).
Result:
• IRA terminated and full amount taxable, plus penalties
Taxpayer of the Year
• T.C. Summary Opinion 2015-47
(Escalante)
• 2005: teacher hours 618, rental 2,450.
• Taking an hour to write a check.
• Working 25 hour days.