Friday, February 13, 2015

News and notes

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News of a tremendous marketing and tax scam arrangement involving biblical manuscripts and evangelical seminaries is covered by Paul Barford and Roberta Mazza. (I am a bit busy to get into this right now, but if someone else is following things and wants to post on this subject it would probably be helpful.)

Fires in Moscow and New York highlight the fact that even manuscripts in major libraries are not imperishable - get those manuscripts photographed (please!). (we already noted CSNTM’s plans for Athens)

Interesting brief discussion from about the possible impact of the increasing availability of digital images of manuscripts: Digitization and manuscripts as visual objects: effects of a media change 

Anne Marie Luijendijk’s new book on the Gospel of the Lots of Mary has been published, and there are some reviews and notes about (e.g. RBECS; BMCR; Larry Hurtado’s Blog; James Snapp’s blog [with pictures])

The 28th International Congress of Papyrology will be held in Barcelona in August 2016. The organisers write: “We congratulate ourselves and very much look forward to host a new edition of our periodic gatherings, where we traditionally share scientific knowledge and human experiences.” If you are planning that far ahead information is available here.

If All The Bible Translations Had A Dinner Party.

Roger Pearse has written a paper on “Ancient chapter divisions, chapter headings, and tables of contents: a preliminary survey of the question” (he blogs about it here)

Brice Jones notes a new agraphon (of Jesus) in P.Monts.Roca 4.59 (V/VI): “It has been retained to pronounce sweet words.” (yes, not too clear, I know; but it could be an agraphon about textual criticism, since the context seems to be a dispute about wording)

Lee McDonald bravely attempts a 322 word answer to the question - When did the early Christians consider the New Testament or rather, some books of the New Testament, scripture? (I wouldn’t have said it quite like this, but would have taken longer!)

N de Lange is doing the second half of his Grinfield Lectures in the Septuagint in Oxford (March 2-4)

29 comments :

  1. I covered the Gospel of the Lots of Mary too, at http://www.thetextofthegospels.com/2015/02/the-coptic-gospel-of-lots-of-mary.html , with a brief comparison of its oracles to the hermeneiai found in some MSS.

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    1. Thanks for that. I've added a link above.

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  2. Certainly bizarre stuff, but tax scam?

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  3. A scam is a kind of confidence trick with the aim to defraud. (According to wikipedia!)

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  4. The way this works is you pay $333,333 for a papyrus fragment of the NT. The same people who sell you this will also give you a valuation which declares this papyrus fragment is worth $1,000,000. You give this to a seminary. You get tax deductions worth $1,000,000. The company gets $333,333 (minus whatever they paid the broke PhD student or unemployed NT Textual Critic for the scholarly evaluation, minus costs [palmolive, warm water, large sink etc.]). So there are two victims of the fraud: i) the clients (they love the 2/3 discount of course, but never asked about the cost price); ii) the state (they are cheated of the tax revenues). There are other possible victims further back as well (e.g. the scholars who will never have any confidence in the details of the manuscript; the family whose scroll was stolen by the Nazis; the student who discovers this 800 year old scroll is only 200 years old; or 50 years old; or made last month in a fake-factory, the plausibility of evangelical biblical scholarship, etc. etc. ).

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    1. I don't see the scam yet. If the IRS-approved appraisers are really independent of the seller, there's no fraud in the tax valuation of the item. And the US government is only "cheated" on tax revenues because of its own tax policy regarding gifts. If the you decide to sell it at the newly valued price, then you pay taxes on that obviously. As for the buyer, surely they realize they're paying something of a markup price. So who's being defrauded? Maybe I'm just naive though!

      Lots of other real and potential problems with this, I agree.

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    2. The scam is that the tax deduction is only permitted for its "fair market value," which is not necessarily the appraised value. What the IRS looks for as strong evidence of a fair market value is a recent transaction of the good, which in this scenario happens to be at a grossly lower price than its purported appraisal. If the IRS had the resources to police / audit these deductions, they may disallow the deduction with penalties and interest (which add up) or even assess additional penalties and/or incarceration for filing a willfully fraudulent tax return.

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  5. Same principle: http://www.ebay.com/bhp/true-cross-relic or http://blogs.telegraph.co.uk/news/tomchiversscience/100229231/the-holy-foreskin-the-relic-of-the-true-cross-and-other-wonderful-forgeries/

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  6. Peter,
    I’m not convinced that what you described is what the Ancient Assets Investments is doing (or proposing to do). Let’s frame a hypothetical scenario:

    (1) The family of a deceased collector in Europe wants to sell the collector’s collection of New Testament antiquities. They have the items in the collection appraised. They realize that if they went through the hassle of selling each item individually at auctions, giving commissions, etc., the items would be sold at higher prices, reaching or exceeding the appraisal-prices. But they want the money now.
    (2) AAI’s purchasing agent offers to pay the family a specific amount for the entire collection – a “bulk purchase,” something that was mentioned in the video.
    (4) The family sells the entire collection to AAI’s purchasing agent.
    (5) AAI’s specialists sort through the collection, looking for things the collection-appraiser might have missed (such as bindings, palimpsest-pages, interesting colophons, etc.), and separate the collection into sub-collections of special interest to some collectors.
    (6) Each item is then re-appraised individually. As part of the initial collection, an item’s value might have been significantly lower: mathematically, one piece of a 50-piece collection sold as a bulk purchase for $250,000 is worth $5,000. But an appraiser might assign a much higher value to that particular piece, possibly $15,000 or $20,000. (At the same time, forgeries may be detected at this stage, in which case AAI would probably just have to swallow the loss.)
    (7) AAI privately sells an individual item to a purchaser for far less than its new appraised value.
    (8) The new owner donates the item to a museum and gets a tax deduction for the item’s appraised value (either the amount of money that this individual item would be insured for, if lost, or which it would be likely to sell for on the open market, depending on tax-law).

    I don’t see anyone getting robbed in that scenario. How is that a scam?

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  7. OK, well I'm no financial expert. I'm as broke as the next soon-to-be-unemployed academic. But this scenario is based on a confidence trick. A clever one in which it is in everyone's interest to have the highest possible valuation, but never to actually test the valuation at auction. The confidence trick is in persuading everyone along the line that they would be better off than selling or buying at auction, and then in setting the price. It does not seem to be based in any particularly realistic appraisal of the prices, but because of the tax advantanges it is not in the interests of the buyer to get the cheapest possible price.

    Imagine they are selling something else: this monograph is really worth $100, but I'm willing to sell it to you for $33, but I'll give you a receipt for $100 so you can claim it on your book expenses.

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    1. No, the receipt would be for $33 with the assumption on both sides of the sale that the item is probably worth $100 on the market. The scenario you describe is exactly what the website claims not to do in that AAI "is not an appraisal service and does not determine the actual Fair Market Value of any item." So they are not giving the appraisal that the IRS uses to determine the tax deduction. If they did, it would be a scam, I agree. But then they probably wouldn't make a public website about it either.

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    2. I guess I am a bit skeptical about the independence of the appraisal.

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  8. Well, i'd have to see more information along the lines of what Stephen posted re: the IRA's rules for such valuations before i'd commit to calling it a scam.

    Certainly there's nothing in principle to object to, since there are accepted precedents all over society where the accepted tax value is different than market value. In north America, at least, if you buy a used car the tax is calculated on the "redbook" value, not the actual sale price. But in that case, the "redbook" is an officially sanctioned listing of car values.
    Similarly, in Canada anyway, your municipal property tax is calculated based on the assessed value of your house, not what you actually paid. In that case, again, an officially sanctioned agency conducts the appraisal.

    So I have no issue, morally, with them assessing a different tax value than the paid market pricem

    I don't even have an issue with the paid price being that much lower, since the difference would simply constitute a donation to the seminary, which too is an accepted practice.

    So the only real concern is whether the IRA has specific rules about such valuations.

    This reminds me of the many evangelical mechanic ministries: they take donated cars and use them to teach mechanics to street kids, thereby both giving them a marketable trade and getting them off the streets. But they need the donated cars. To get them, they advertise to the public that you can donate your car for free but the ministry will issue you a tax receipt for the full redbook value of the car. Now, in that case it is all perfectly legal because the redbook was made precisely for that purpose.
    But the IRA doesn't have a "redbook" for manuscripts, so what laws and guidelines do they have?

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    1. The IRS's standard is "fair market value." None of your examples involve an appraisal that is grossly higher than a recent market price, when the structure of the transaction looks like it's designed to obtain a massive tax deduction. It's been about twenty years since I took income tax in law school, so I don't have the case cites at hand (or even recent ones), but this looks just like the kind of tax scams that get people into a lot of trouble. Those appraisals don't mean anything if they are far out of line with what the IRS thinks is the fair market value, particularly when there's a recent receipt for it at a third of the price.

      Obviously, if one is seriously interested in such a financial arrangement one should consult a competent tax attorney (not me), but let's not be naive here about thinking that an "independent" appraisal is all that you need to avoid the IRS coming down hard on you.

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    2. So as far as tax credit goes, the appraisal is pointless is that right, Stephen?

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    3. Thanks Stephen, not to be nitpiky, but both those examples often do involve quite a discrepancy between the assessed value and the latest paid price. For houses, for example, MPAC makes it clear on their website that they do not take paid price as the basis for their assessment. My house was just assessed for $180k more than we paid for it last year.

      For cars, paid price often differs greatly from assessed redbook value, particularly if the used car sale is actually part of a trade in deal with a new car dealer, but especially if the used car is actually being gifted. It is common for family to gift an old car to, say, their children for a token payment of like $1 or $100, but then the recipient still has to pay tax on the full redbook value.

      That last example is perhaps most comparible, since gifts and donations to seminaries is common practice.

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    4. These are attempts to assess the fair market value over a longer term, with items well-understood known to appreciate and depreciate in fairly predictable ways. That's not the scenario with these fragments where there is not a competitive market and the idea is to churn the purchase in the short term with a high mark up, assessed only for purposes of a tax deduction. Plus, both your example involve an increase in tax liability--no tax scam there, well at least by the individual.

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  9. So the North Americans think this is all OK. Maybe I shouldn't have called it a scam. I could call it an interesting financial arrangement.

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    1. I spoke too soon, assuming Stephen is happy with the label 'North American' (which I used to be inclusive w.r.t. Ryan!). He seems happy with the term "scam", and he is (presumably) the only lawyer among us.

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    2. Was happy with the label "North American"?

      Or was a lawyer?

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    3. More the latter than the former.

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  10. Insurance is calculated in a similar way. Regardless of what one paid (or didn't pay) for an item, a value is placed upon the item by an outside auditor/expert. Then an insurance policy is written up with that assessed value.

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  11. I emailed Todd Hillard tonight with some questions and concerns about AAI and he has now taken the site down. He seems open to constructive feedback. See his comment at Roberta Mazza's blog.

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  12. Ryan,
    I think you mean the IRS, not the IRA.
    That's something different. At least a little.

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    1. Yup! Funny, but easy mistake, for a canuck to make, though I would bet a lot of Americans might say I was righter than I knew!

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  13. I recommend reading this: http://paul-barford.blogspot.co.uk/2015/02/todd-hillard-up-front.html
    I think this story is a complicated mix of many different things, stemming from gigantic ignorance. I personally believe Torah scrolls and ancient artefacts cannot be sold and bought as any other kind of goods, but of course this is my personal opinion on the matter. I found very disturbing, disrespectful the way the Torah scrolls were 'dedicated' through Christian prayers.

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