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Private Letter Ruling 201245004

Proskauer Rose LLP
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USA
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February 12 2013

The IRS ruled that the surviving spouse could disclaim her interest in an Individual Retirement Account ("IRA") even though she had received

IRS issues Revenue Procedure 2013-15

Proskauer Rose LLP
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USA
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February 12 2013

In Revenue Procedure 2013-15, the IRS announced the 2013 inflation adjustments, including the income tax rate schedules, and other tax changes

Estate of Nancy P. Young v. United States (D. Mass., No. 1:11-cv-11829-RWZ, 121712)

Proskauer Rose LLP
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USA
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February 12 2013

In Estate of Nancy P. Young v. United States, the District Court upheld a latefiling penalty against an estate whose accountants advised it to file

We didn't (quite) fall off the cliff, but we still have to clean up the mess!

Proskauer Rose LLP
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USA
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January 8 2013

When the clock struck midnight on December 31, 2012, estate planning practitioners said "good night" to an unprecedented period of working with clients to

Rev. Proc. 2012-14 (10182012)

Proskauer Rose LLP
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USA
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December 7 2012

The IRS released the inflation adjustments affecting various sections of the Internal Revenue Code for 2013

Estate of Bates v. Commissioner, T.C. Memo. 2012-314, November 7, 2012

Proskauer Rose LLP
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USA
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December 7 2012

The Tax Court ruled that the cost of settlement could not be deducted as an administrative expense on an estate tax return, because the claim was for a beneficiary's distributive share and not for a creditor's claim against the estate

Estate of Thouron v. United States, E.D. Pa., no. 2:11-CS-04058 (11082012)

Proskauer Rose LLP
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USA
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December 7 2012

The U.S. District Court for the District of Pennsylvania held that relying on the advice of a tax attorney was not reasonable cause for the late payment of estate taxes

Internal Revenue Bulletin 2012-46 (11132012)

Proskauer Rose LLP
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USA
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December 7 2012

The IRS said that it does not acquiesce in the Tax Court's March ruling in Wandry v. Commissioner, despite the recent withdrawal of the government's appeal

Private Letter Ruling 201236022 (09112012)

Proskauer Rose LLP
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USA
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November 15 2012

In this PLR, the Internal Revenue Service ("IRS") ruled that amounts paid to charities from the residue of the decedent's estate pursuant to a settlement agreement qualified for the charitable deduction for federal estate tax purposes because the charities had an enforceable right under state law to receive a portion of the residuary estate due to the undue influence by the drafting attorney (who was also a beneficiary

Scaggs v. Comm'r, T.C. No. 16342-11, T.C. Memo 2012-258 (09102012)

Proskauer Rose LLP
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USA
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November 15 2012

The United States Tax Court upheld the denial of a taxpayer's petition for redetermination of deficiencies and accuracy-related penalties because the taxpayer did not use a designated private delivery service

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