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Results: 1-10 of 146

Tax Court refused to admit appraisal into evidence when taxpayer failed to qualify the appraiser as an expert witness
  • Proskauer Rose LLP
  • USA
  • January 9 2014

In Tanenblatt v. Commissioner, the Tax Court made clear that it would not allow a taxpayer to circumvent the Federal Rules of Evidence or the Court's


Income tax is payable on proceeds from surrender of a life insurance policy used to repay a loan against the policy
  • Proskauer Rose LLP
  • USA
  • January 9 2014

In a recent income tax case, the Tax Court affirmed the principal that the proceeds received from surrender of an insurance policy in excess of the


New York considers raising estate tax exemption, reinstating gift tax, eliminating GST tax and closing the resident trust loophole
  • Proskauer Rose LLP
  • USA
  • January 9 2014

On November 14, 2013, the New York State Tax Reform and Fairness Commission presented its final report to the Governor containing various


Rev. Proc. 2012-14 (10182012)
  • Proskauer Rose LLP
  • USA
  • 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
  • USA
  • 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
  • USA
  • 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
  • USA
  • 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


IRS extends interim relief to trusts and estates on investment advisory costs - Notice 2010-32
  • Proskauer Rose LLP
  • USA
  • May 7 2010

The IRS recently issued Notice 2010-32, which extends for another year interim relief for trusts and estates on the treatment of investment advisory costs subject to the 2 floor under 67(a), so that taxpayers will not be required to determine the portion of a bundled fiduciary fee that is subject to the 2 floor for any taxable year beginning before January 1, 2010


Federal district court finds transfer of interests in LLC to children does not qualify for the annual gift tax exclusion Fisher v. Commissioner, No. 1:08-CV-00908 (March 11, 2010)
  • Proskauer Rose LLP
  • USA
  • May 7 2010

A U.S. District Court in Indiana found the transfer of interests in a LLC to children did not qualify for the annual gift tax exclusion because the interests were considered “future” rather than “present” interests in property due to operating agreement restrictions on the children’s rights relating to the property


April interest rates remain steady for GRATs and split interest charitable trusts and increase slightly for sales to defective grantor trusts and intra-family loans
  • Proskauer Rose LLP
  • USA
  • April 16 2010

The April applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3