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Recent Articles & Treatises
- Registration now open for September 17, 2019 CPE Seminar, “IRC Sec. 199A: Wasn’t the Code to be Simplified?” August 26, 2019
- A Journey Through IRC Section 199A: Wasn’t the Code to be Simplified? July 25, 2019
- Tax News & Comment — August 2019 July 25, 2019
- Tax News & Comment – April 2017 March 13, 2017
- Tax News & Comment — May 2016 May 14, 2016
- FROM WASHINGTON & ALBANY — Current Election Probabilities; Tax Plans of Trump and Clinton May 13, 2016
- FROM FEDERAL AND NYS COURTS: Recent Developments & 2015 Decisions of Note May 13, 2016
- IRS & NYS DTF MATTERS: Recent Developments & 2015 Regs. & Rulings of Note May 13, 2016
- Creating and Maintaining Flexibility in Wills and Trusts May 13, 2016
- Escaping the Quandary Posed by Unreported Foreign Accounts May 13, 2016
- Like Kind Exchanges Alive and Well: An Update May 13, 2016
Most Popular
- September 17 CPE Breakfast Lecture in Old Westbury, New York -- "IRC Sec. 199A: Wasn't the Code to be Simplified?"
- Taxation of Foreign Nongrantor Trusts: Throwback Rule
- Use of Disclaimers in Pre and Post-Mortem Estate Planning
- Depreciation Recapture
- Defeating The Right of Election in EPTL § 5-1.1-A
- Executor and Trustee Commissions Under NY EPTL
- Lawyers
- Living Wills
- Gain, Loss and Depreciation Issues in Like Kind Exchange
- Tax and Legal Issues Arising In Connection With the Preparation of the Federal Gift Tax Return, Form 709 -- Treatise
Category Archives: Gift & Estate Tax Decisions of Note
IRS & NYS DTF Matters: Recent Developments & 2013 Regs. & Rulings of Note
I. IRS Matters Final Regulations For Health Insurance As of January 1, IRC § 5000A requires that all “non-exempt” individuals obtain “minimum essential healthcare coverage.” Final regulations governing penalties for noncompliance have been issued. (T.D. 9632). The regulations provide, inter … Continue reading
Posted in Gift & Estate Tax Decisions of Note, IRS, IRS Matters, IRS Rulings & Regulations, NYS Dept. of Tax'n & Finance
Tagged delaware nongrantor trusts, Health Insurance Regulations, irs, late s corporation election, mcneil v. Pennsylvania, net investment income tax, nys suspension of drivers' license tax, nys warrantless income executions, option reporting for brokers mandatory, PLR 201310002, regulations for tangible property, relief from unnecessary qtip elections, Rev. Proc. 2013-35, Taylor v. NYS Tax Commission, treasury
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2012 Gift & Estate Tax Decisions of Note
View in PDF: Tax News & Comment — February 2013 2012 Gift & Estate Tax Decisions of Note I. Formula Clauses The Tax Court in Wandry v. Com’r, T.C. Memo 2012-88, nonacq., 2012-46 I.R.B. upheld a defined value clause containing … Continue reading
Posted in Gift & Estate Tax Decisions of Note, Gift Tax Planning, News, Tax Decisions, Tax News & Comment
Tagged Abatement of Penalties, Adequate Disclosure, Administration Expenses, applicable exclusion amount, asset protection trusts, Charitable Contributions, Claims for Refund, Conservation Easement, estate attorney, Estate Planning with, Estate Planning with Family Entities, Estate Tax Returns, formula clauses, gift tax returns, Protective Claims, Protective Refund Claims, Revenue Procedures, Revenue Rulings, tax attorney, Tax Court, tax lawyer, valuation discounts, wandry v. commissioner
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Tax Court Defies IRS: Expands Use of Defined Value Clauses
View Article in Tax News & Comment — October 2012 TAX COURT DEFIES IRS: EXPANDS USE OF DEFINED VALUE CLAUSES The recent loss by the IRS in the Tax Court case Wandry v. Com’r, T.C. Memo 2012-88, added to the … Continue reading
Posted in Defined Value Clauses, Estate Planning, From the Courts, Gift & Estate Tax Decisions of Note, News, Tax Decisions, Tax News & Comment
Tagged christiansen v. commissioner, defined value clauses, estate attorney, formula clauses, formula clauses adjusting transfer, formulas that define consideration, formulas that define transers, IRS revaluation of gifts, mccord v. commissioner, petter v. commissioner, procter v. commissioner, proctor v. commissioner, tax attorney, tax lawyer, value of transferred property, wandry v. commissioner
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2011 Tax and Estate Planning Decisions of Note
A. Issues Arising Under IRC §2036 An important objective in estate tax planning is to transfer of assets out of one’s taxable estate, while retaining a degree of beneficial enjoyment over the transferred property. Where the IRS believes too much … Continue reading
Tax Court Holds Single Member LLC Not Ignored for Gift Tax Purposes
Pierre v. Com’r, 133 T.C. No. 2 (8/4/09) Continue reading
2007 Estate & Gift Tax Cases
The 11th Circuit, reversing the Tax Court, held that an estate properly reduced the value of the decedent’s interest in a company holding marketable securities by the company’s entire $51 million built-in capital gain tax liability. Estate of Jelke Est. … Continue reading
Law Offices of David L. Silverman 
From Federal Courts, NYS Courts & Tax Tribunals — Recent Developments & 2014 Decisions of Note
I. Disputes Involving Sales of Assets to Grantor Trusts Reach the Tax Court In Estate of Woelbing v. Com’r, Docket No. 30261-13, filed on December 26, 2013, the IRS made several arguments seeking to negate the tax benefit sales of … Continue reading →