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Daily Archives: March 24, 2010
Installment Sale Reporting of Deferred Exchange Boot
IRC §453 provides that an “installment sale” is a disposition of property where at least one payment is to be received in the taxable year following the year of disposition. Income from an installment sale is taken into account under the “installment method,” whereby income recognized in any taxable year following a disposition equals a proportion of the payments received, that proportion being equal to the gross profit over the total contract price. Continue reading
Posted in Federal Income Tax, Like Kind Exchanges
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General Power of Appointment Can Neutralize Estate Tax
A general power of appointment is power of appointment that is exercisable in favor of the donee, the donee’s creditors, or the creditors of the donee’s estate. Under IRC § 2042, the value of property over which the donee possesses a general power of appointment at death is included in the donee’s estate. Continue reading
Posted in Estate Planning, General Power of Appointment
Tagged 2523(f), applicable exclusion amount, appoint trust assets, completed gift, credit shelter, credit shelter trust, equalize, equalize estates, general power of appointment, PLR 200101021, PLR 200210051, PLR 200403094, PLR 200604028, QTIP, testamentary general power of appointment, unequal estates
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Law Offices of David L. Silverman 