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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


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.”


Recent case points out even more risks of serving as fiduciary
  • Loeb & Loeb LLP
  • USA
  • August 16 2012

By now most people are aware that significant legal and economic exposure goes along with serving as a personal representative or trustee for a close friend or family member


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


Estate denied deduction for settlement payment to caregiver
  • Loeb & Loeb LLP
  • USA
  • January 24 2013

In Estate of Sylvia E. Bates (2012), the Tax Court rejected an estate's attempt to deduct a settlement payment to the decedent's caregiver as an


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


More family limited partnerships in court
  • Loeb & Loeb LLP
  • USA
  • April 24 2012

Several recent cases have addressed tax issues related to family limited partnerships or limited liability companies


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


More mixed results in litigation of family limited partnership cases
  • Loeb & Loeb LLP
  • USA
  • September 14 2009

The enormous tax dollars at stake in connection with valuation discounts for estate and gift tax purposes is evidenced by the never ending stream of family limited partnership cases