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Two taxpayers lose income tax deductions for spousal support payments

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • September 5 2013

Two recent Tax Court cases serve as a reminder that the income tax deduction for the payment of spousal support is subject to some very specific rules

Private letter ruling suggests that assets held in a grantor trust and not included in grantor’s estate may nevertheless receive a basis increase

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • May 20 2013

In PLR 201245006, the IRS addressed a question that has been puzzling tax advisors for years. A person who was not a citizen or resident of the

Fifth Circuit reverses Tax Court on amount of discount allowed in determining estate tax value of works of art

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • December 23 2014

We previously reported on the Tax Court case Elkins v. Commissioner (March 11, 2013) (Vol. 8, No. 2, May 2013). At issue was the value, for estate

IRS moves against incomplete gift strategy

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • April 24 2012

For a long time, a popular tax-planning strategy has involved the use of an “incomplete gift.”

Co-op shareholder cannot deduct amount of assessment to repair damage

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • August 2 2011

A recent Tax Court case serves to point up one of the distinctions between owning your home outright and owning your home through the ownership of shares in a residential cooperative corporation (“coop”

New York estate and trust tax changes: the good, the bad and the ugly

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • April 10 2014

As we noted in our recent client alert, New York Governor Andrew Cuomo announced in January that he would introduce legislation intended to reduce

IRS issues ruling favorable to “intentionally defective grantor trusts”

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • August 26 2008

The so-called “Intentionally Defective Grantor Trust” (“IDGT”) has become a very popular estate planning technique

What is the statute of limitations for the overstatement of the income tax basis of an asset?

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • November 21 2007

In general, the IRS has a period of three years from the later of the due date of a federal income tax return or the date on which it is actually filed to assess additional taxes with respect to that return

Court approves defined value clause for gift where excess value retained by donor

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • April 24 2012

The U.S. Tax Court has held for the first time in Wandry v. Commissioner (Tax Court, March 26, 2012), that a donor may make a non-cash gift of a stipulated dollar amount and retain any portion of the transferred property value in excess of the stated dollar amount the donor gave away

IRS clarifies application of passive loss rules to trusts

  • Loeb & Loeb LLP
  • -
  • USA
  • -
  • November 21 2007

Under IRC 469, losses incurred by individuals (including estates and trusts) in connection with passive activities are deductible only to the extent that the taxpayer also has income from passive activities