Charles Richardson

670 posts

Charles Richardson

Charles Richardson

@viachicago99

Katılım Nisan 2009
832 Takip Edilen110 Takipçiler
Reason and analytics in Dallas
Reason and analytics in Dallas@DallasAnalytics·
@viachicago99 @epictrades1 @RedDogT3 I mean the market is going to do what the market is going to do, but Lisa Su just told us yesterday they have line of sight into massive future earnings and accordingly they are upgrading this thing like crazy. Doesn't make a lot of sense that she is selling off.
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The Inner Circle Trading Group DP David Prince
$AMD PT raised to $1,250 from $625 at Baird $AMD PT raised to $730 from $700 at UBS $AMD PT raised to $620 from $560 at BofA $AMD PT raised to $650 from $500 at Roth Capital $AMD PT raised to $660 from $540 Melius Research
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Charles Richardson
Charles Richardson@viachicago99·
@Josh_Hamlet Thanks. I knew the wherewithal to pay argument was only based on legislative history, not Constitutional precedent, but I’ll never understand how it’s not a larger consideration.
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Josh Hamlet
Josh Hamlet@Josh_Hamlet·
Moore isn’t really the obstacle, and the Court kept it deliberately narrow. Kavanaugh limited it to attributing an entity’s realized income to shareholders and expressly left unrealized appreciation and mark-to-market for another day. The Moores’ CFC had realized income. The gross winnings here are realized too. Congress just won’t let you subtract against them. And wherewithal to pay was never a constitutional doctrine. It explains why Congress defers tax in 1031 and installment sales. It’s never been a limit on what Congress can reach. The actual wall is New Colonial Ice: deductions are a matter of legislative grace. Cannabis companies tried a similar argument against 280E (gross receipts, 16th Amendment) and lost. One major difference though: the 280E cases leaned on the underlying activity being illegal. There’s no illegality hook here. So the precedent isn’t a perfect fit, it’s just the closest thing to one.
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Josh Hamlet
Josh Hamlet@Josh_Hamlet·
Last week I testified at the IRS hearing on the 90% gambling loss cap from a beach in Spain. The static everyone heard was the sea. Then the sea hung up on me mid-argument. I have now testified before a federal agency for less time than the average WSOP main event tank. A week to digest, and here's what sticks. Everyone at that hearing knew the rule taxes money nobody made. Win 500k, lose 500k, owe tax on 50k. Congress knew the math when it wrote the provision. It passed anyway, because gamblers have no defenders in a markup. And there's no upside to trade against. The projected revenue assumes people keep betting where the IRS can see them, while the former bookie who testified says the money goes offshore and underground where nothing gets reported at all. Follow it through and this rule is an administrative nightmare (matching notices built on phantom numbers), an ethical one (the burden lands entirely on honest reporters), a legal one (an income tax should require income), and a public health one (the players least able to absorb it get pushed to unregulated markets). Full testimony below, including the part the ocean kept off the record. @fairplaygov @PokerCPAs @ToddWitteles @repdinatitus @SaraSmartist
Josh Hamlet tweet mediaJosh Hamlet tweet mediaJosh Hamlet tweet media
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Charles Richardson
Charles Richardson@viachicago99·
@Josh_Hamlet Thanks for this, great article. Is Moore v. The United States a killer for making the wherewithal to pay argument?
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Charles Richardson
Charles Richardson@viachicago99·
@Josh_Hamlet The provision is insanity. And allegedly no Senator knows where it originated. “numerous Senators have expressed confusion about the provision’s origins. Sen. Charles E. Grassley (R-IA), a member of the Finance Committee, stated “[i]f you’re asking me how it got in there….
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Charles Richardson
Charles Richardson@viachicago99·
@bdl4186 @JonahLupton He’s trying to call a bottom the first day of a breakdown from a 6-9 month range. I’ll never understand why people feel the need to do this.
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BDL
BDL@bdl4186·
@JonahLupton This is close to earning an unfollow
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Jonah Lupton
Jonah Lupton@JonahLupton·
What if Elon is trying to push $TSLA stock lower so $SPCX can buy it cheaper?
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Kris Weiss
Kris Weiss@kris_weiss52190·
@tomandmartys It's a 500 yards par 4. What do you want him to use wedge
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Larry @Tom & Marty's
Larry @Tom & Marty's@tomandmartys·
I get Cam Young getting aggressive with driver off the tee. But the moment it went into the bunker he should’ve gone into par save mode. Just a dumb as hell second shot there. If -10 wins it, he’ll be haunted by that choice. Well at least I will be.
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Aisar
Aisar@aisarcore·
A professional poker player found a manufacturing flaw on the back of a deck of casino playing cards. He used it to win $19 MILLION at two casinos on two continents. Courts on both continents ruled it was cheating and made him give almost all of it back. – Phil Ivey is a ten-time World Series of Poker bracelet winner. – Widely considered one of the best professional gamblers alive. – In April 2012 he booked a private high-stakes baccarat session at the Borgata in Atlantic City. – He wired a $1 MILLION deposit up front. – He made specific requests. A private pit, a Mandarin-speaking dealer. – His guest Kelly Sun seated beside him. One single deck of purple Gemaco cards for the entire session. An automatic shuffler. – The Borgata agreed to all of it. – Sun had spotted something. Certain decks had a tiny factory defect. A slightly uneven diamond pattern on the card backs. – She asked the dealer to rotate specific high-value cards 180 degrees. – Told him it was superstition. For luck. – It wasn't luck. – Once enough key cards were flipped, she and Ivey could read the edge of the next card in the shoe before it was dealt. – Ivey bet accordingly. – Four visits to the Borgata in 2012 and he won $9.6 MILLION. – Same trick, different casino. – Crockfords in London. Just under £8 MILLION was won playing punto banco. – Crockfords caught the pattern and refused to pay. – Ivey sued them, he argued it wasn't cheating, just exploiting how the casino chose to deal. – The case reached the UK Supreme Court. All five judges ruled against him. – They said he took deliberate steps to fix the deck. – Meanwhile, the Borgata had already paid him his $9.6 MILLION back in 2012. – Once they found out how, they sued to get it back. – A US court ruled it wasn't technically fraud. But it broke New Jersey's Casino Control Act. – Ivey was ordered to repay $10,130,000. – He appealed. The Borgata spent years trying to actually collect, at one point seizing his winnings at the World Series of Poker. – In July 2020, eight years after the first hand was dealt. Ivey and the Borgata settled. Terms never made public. He never touched a card, never marked one. He just asked a dealer to turn a few of them around "for luck." Two countries' highest courts still called it a con.
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Charles Richardson
Charles Richardson@viachicago99·
@ZakHowells Oh I thought he hit an 8. So a little further from the wall than Fox, he probably would have been good with an 8.
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Zak Howells
Zak Howells@ZakHowells·
@viachicago99 And he was definitely a little further from the wall. As soon as he was lining that up with a 7 it never looked like making it out the bunker. He actually got lucky with where it ended up, deserved to just stay in the bunker. Something he will regret big time.
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Zak Howells
Zak Howells@ZakHowells·
Absolutely insane set of decisions down 18 for Cameron Young. Had to take his medicine and post 10 under.
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Charles Richardson
Charles Richardson@viachicago99·
@ZakHowells Agreed. Once you’re in that bunker you have to play for a 5 and hope you make 4. I assume he saw Fox’s shot yesterday hit the lip of that bunker (still somehow made the green). I believe they said Fox hit an 8 iron yesterday so I think you have to just hit a 9 iron there.
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Zak Howells
Zak Howells@ZakHowells·
@viachicago99 I still think the decision out of the bunker was ludicrous. Couldve set himself up better to make a par and be 10 under.
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Charles Richardson
Charles Richardson@viachicago99·
@ZakHowells Watching Fox’s perfect drive just now, there are three bunkers one after the other down the right side of that fairway so it’s not as simple as hitting it short of the bunkers. Your decision making is absolved Cam 🤣
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Charles Richardson
Charles Richardson@viachicago99·
@ZakHowells I know he was hitting his driver great today but he had to hit 3 wood off the tee and take that bunker out of play. With how far the ball is rolling he still would have had a short/medium iron for his second shot.
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Charles Richardson
Charles Richardson@viachicago99·
@ZakHowells Especially after hitting his drive into the same bunker yesterday and making bogey.
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Lovin'Life
Lovin'Life@LakeLifeIsGreat·
@fox32news I live in Tennessee. We don't have high property taxes. We don't even have state income taxes. We don't put additional taxes on millionaires. We have good roads, police are paid, schools are pretty decent. I don't understand why some of the blue states can't do the same thing.
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FOX 32 News
FOX 32 News@fox32news·
Former Illinois Governor Pat Quinn says Illinois homeowners are paying some of the highest property taxes in the nation, and he believes a new tax on millionaires could help provide relief. fox32chicago.com/news/former-go…
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Aya
Aya@Aya_Research·
The Apple analogy has a hinge nobody names: Apple re-rated when the market decided iPhone demand was recurring, not episodic. That's the open question for $NVDA — does accelerator demand behave like a subscription (3-5yr refresh cycles, locked ecosystem) or a buildout (one roof, done)? CUDA lock-in argues the first; every customer designing its own silicon argues the second. The re-rating holds exactly as long as the refresh cycle does.
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Tom Lee Tracker (Not actually Tom)
TOM LEE: NVIDIA $NVDA IS HAVING ITS APPLE $AAPL MOMENT AND THE RE-RATING MAY NOT BE OVER He compares Nvidia to the way Apple was once viewed: - Apple used to be seen as a hardware phone maker that should trade around 10x earnings - Then it re-rated closer to 30x as investors understood the business differently - He thinks a similar re-rating can still come for Nvidia, even with big expectations heading into earnings
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Dan Rapaport
Dan Rapaport@Daniel_Rapaport·
I want to see no damn watering of Shinnecock Hills this evening. Do not tame the beast any longer. Bring on some damn chaos.
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Baseball Egg
Baseball Egg@baseballegghead·
@Tonysmarkettips If you didn't know he was doing magic TRICKS before Torre's podcast, you were a massive idiot. God. We live in the most uninformed times.
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Tony Farmer
Tony Farmer@Tonysmarkettips·
Mike Vrabel and Dianna Russini are having a tough offseason but not as bad as Oz Pearlman the Mentalist. Will we ever hear from that guy again? Is there any coming back from the what Pablo did to him?
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