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  • Limited partner or assignee interest: Tax Court sides with IRS

    March / April 2019
    Newsletter: Advocate's Edge / Litigation Support

    Price: $225.00, Subscriber Price: $157.50

    Word count: 898

    Abstract: Wealthy taxpayers sometimes incorporate family limited partnerships (FLPs) in their estate plans to help minimize federal estate and gift taxes. Historically, the IRS has been aggressive in challenging such arrangements. This article summarizes a recent case in which the U.S. Tax Court sided with the IRS, offering a valuable reminder that, when it comes to the federal tax effect of intrafamily transfers of interests, labels aren’t determinative. Rather, the court will consider the substance of the transaction. A sidebar explains how the court handled valuation discounts. Estate of Streightoff v. Commissioner, T.C. Memo. 2018-178, Oct. 24, 2018

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  • Work-related education – When can you deduct your expenses?

    May / June 2011
    Newsletter: Tax Impact

    Price: $225.00, Subscriber Price: $157.50

    Word count: 898

    Abstract: Those heading back to the classroom to improve their marketability may, depending on their income level and other factors, qualify for education tax credits (such as the Hope credit or Lifetime Learning credit) or the tuition and fees deduction. But this article focuses on deducting the cost of education as a business expense. It explains what is and is not deductible, and one instance in which an unemployed person might be able to deduct expenses. A sidebar addresses the issue of whether the cost of obtaining an MBA is deductible.

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  • Fraudulent transfer laws – Don’t let creditors undo your estate plan

    August / September 2010
    Newsletter: Insight on Estate Planning

    Price: $225.00, Subscriber Price: $157.50

    Word count: 898

    Abstract: Most people wouldn’t even consider transferring or hiding assets to avoid paying their creditors. But the fraudulent transfer laws can also jeopardize perfectly innocent, legitimate estate planning moves. And if creditors challenge gifts, trusts, retitling of property or other strategies as fraudulent transfers, they can quickly undo an estate plan. This article examines the difference between actual vs. constructive fraud, and explains the importance of analyzing one’s net worth before making substantial gifts. A sidebar lists factors that may signal an intent to defraud.

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  • Home run – FLLCs enjoy a Tax Court victory

    January / February 2009
    Newsletter: Advocate's Edge / Litigation Support

    Price: $225.00, Subscriber Price: $157.50

    Word count: 898

    Abstract: In recent years, taxpayers have found themselves on the losing end in cases questioning the legitimacy of FLPs and FLLCs. But, in a 2008 case, Estate of Mirowski v. Commissioner, the U.S. Tax Court threw a curve ball, allowing family FLLC assets to be excluded from the decedent’s gross estate. This article summarizes the case and suggests that taxpayers can use the court’s findings to form and operate these vehicles.

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