The New York Times reports that Anthony Marshall, son of Brooke Astor, has been convicted of larceny and defrauded his mother out of tens of millions of dollars after more than three months of testimony and arguments in State Supreme Court...
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Deloitte has published its annual wealth planning guide, "The Essential Tax and Wealth PLanning Guide for 2010: A Year-Round Resource for navigating Change in Today's Economy." The guide may be downloaded by clicking here. Deloitte describes this guide as follows:...
The IRS Small Business/Self-Employed Division has issued interim guidance on the procedures for implementing the gross valuation misstatements penalty attributable to incorrect appraisals under section 6695A.See Tax Analysts: "IRS Issues SB/SE Interim Guidance on Gross Valuation Misstatements Penalty," 2009 TNT...
The IRS has allowed an entity permission to be classified as a liquidating trust for federal income tax purposes and has concluded that the trust will be a grantor trust and the trust's beneficiaries will be treated as the owners...
Continue reading "IRS Letter Ruling: "Liquidating Trust Classification Granted""
The IRS has allowed an individual an extension to elect out of automatic allocation of the generation-skipping transfer tax under section 2632(c)(5) for transfers to various trusts.See Tax Analysts: "Extension Granted to Elect Out of Automatic Allocation of GSTT," 2009 TNT...
The IRS has determined that a widow who enacted a disclaimer under section 2518 is the sole beneficiary and distributor of her late spouse's IRA. She is allowed to transfer the funds from the IRA to a separate IRA in...
The IRS has determined that income from a trust created by a municipal corporation to fund retiree medical benefits is excludable from the corporation's gross income under section 115 and that contributions to the trust are excludable from a retiree's gross...
Steve Akers, Associate Fiduciary Counsel, Bessemer Trust, provides the following summary of Estate of Murphy vs. United States, U.S. Dist. Ct. W.D. Ark. El Dorado Division, Case No. 07-CV-1013 (October 2, 2009):In another John Porter case, the IRS alleged a...
Roberto Cittadini of Bellevue, Wash., pleaded guilty today to filing a false tax return, the Justice Department and Internal Revenue Service (IRS) announced. Cittadini appeared today before Magistrate Judge Mary Alice Theiler in Seattle and accepted responsibility for concealing nearly...
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In a legal memorandum, the IRS has concluded that the mitigation provisions of the code do not allow taxpayers to reopen a tax year for a refund. Two taxpayers believe they were entitled to a tax refund based on a...
Revenue Ruling 2009-33 provides various prescribed rates for federal income taxpurposes for October 2009 (current month) including the applicable federal interest rates, the adjusted applicable federal interest rates, the adjusted federal long-term rate, the adjusted federal long-term tax-exempt rate. These rates...
Tax Notes has published an article by Wendy C. Gerzog, a professor at the University of Baltimore School of Law, regarding the Miller case (a decision on family limited partnerships (FLPs) with effective line drawing). According to Gerzog, the Miller case...
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Tax Notes has published an article written by Douglas A. Kahn, the Paul G. Kauper Professor at the University of Michigan Law School. The article's main purpose is to refute several points made by Professor Stephen Cohen regarding opinions of...
Ellen Fredel of Ellen Fredel PC, has issued a response to a request for comments on foreign bank account reports. Fredel has endorsed comments by State Street Bank and Trust Co., adding that the Service should not require FBAR filing...
Mary Ann Cohen, a judge on the United States Tax Court, has written an opinion on the case of the Estate of Noordin M. Charania et al. v. Commissioner. The estate of Noordin Charania has petitioned against an IRS ruling...
The IRS has issued the following news release.The Oct. 15 deadline is fast approaching for millions of taxpayers who requested a six-month extension to file their 2008 tax returns.It's also the deadline for special voluntary disclosures by taxpayers with assets...
Steve Akers, Associate Fiduciary Counsel, Bessemer Trust, provides the following summary of Estate of Malkin v. Commissioner, T.C. Memo. 2009-212 (September 16, 2009):IRS Defeats Aggressive FLP Planning; Issues Involving §2036, Indirect Gifts, and Sham Sales and LoansThis Tax Court Memo...
Continue reading "Steve Akers' Summary of Estate of Malkin v. Commissioner"
