IRS Cannot Disavow Revenue Ruling 78-197 to Recharacterize Charitable Donation

Business Valuation Update BVLaw
Legal and Court Case Update
October 7, 2002

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estate and gift taxation
Gerald A. and Henrietta V. Rauenhorst v. CIR
119 T.C. No. 9 (2002)
US
Federal Court
United States Tax Court
Ruwe

Summary

The full Tax Court con­sidered whether the anticipatory assignment of in­come doctrine should be applied to recharacterize the transfer of warrants to four charitable organiza­tions.

See Also

Gerald A. and Henrietta V. Rauenhorst v. CIR

Full Text of Court Cases
October 7, 2002

The full Tax Court declined to permit the IRS to disavow Rev. Rul. 78-197, upon which the taxpayers relied, and, thereby, used the anticipatory assignment of income doctrine to recharacterize the transfer of warrants in a soon to be acquired corporation t ...