Tax Notes has published IRS e-mailed advice that gave guidance on section 6166 passive asset determination, concluding that money owed by a decedent's son's company to the decedent's company and that was still unpaid for 10 to 15 years is not a passive asset because it is not needed for the decedent's active business's conduct.
See "Service Says Debt Not Passive Asset of Decedent's Business", 2009 TNT 131-60 (July 13, 2009)
Posted by Gary Robillard, Associate Editor, Wealth Strategies Journal.

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