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U.S. stock owned by British citizen residing in Belgium included in taxable estate, but penalties abated
  • Sullivan & Worcester LLP
  • USA, Belgium
  • August 1 2010

In an interesting case before the U.S. Court of Appeals for the First Circuit, the estate of Noordin Charania appealed the IRS' determination that all of Noordin's Citigroup stock was includible in his estate and the IRS' refusal to abate an additional penalty assessed during audit.

Alison E. Lothes
  • Sullivan & Worcester LLP

David A. Handler
  • Sullivan & Worcester LLP