Peek v. Commissioner
Tax Court finds taxpayers engaged in “prohibited transactions” under IRC Section 4975(c(1)(B) when making personal guaranties on a promissory note to a company they had bought via IRAs for purposes of deferring until retirement any income tax liability on ...
Foreign-Educated Doctor’s Lost Earnings Computed in Personal injury Action
In Dr. Natheir Al-Hendawi v. Manjit Singh Sidhu, 2006 BCSC 522 (CanLII) (decided March 30, 2006), the Supreme Court of British Columbia calculated. the lost past and future earnings of a medical doctor resulting from an auto accident.
Dr. Natheir Al-Hendawi v. Manjit Singh Sidhu
In Dr. Natheir Al-Hendawi v. Manjit Singh Sidhu, 2006 BCSC 522 (CanLII) (decided March 30, 2006), the Supreme Court of British Columbia calculated. the lost past and future earnings of a medical doctor resulting from an auto accident.
Continuing IRS attacks on reality of pass-through entities
This article pulls together court cases, Field Service Advice (FSAs) and Technical Advice Memoranda (TAMs) that show the courts' and the IRS's positions on the valuations of interests in pass-through ...
An overview of IRS precedential authority
What appraisers need to know about the administrative and precedent authority of IRS pronouncements , Victoria A. Platt, Insights , Autumn 2001, Willamette Management Associates, www.willamette ...
IRC § 1033
LEXSTAT IRC sec. 1033 INTERNAL REVENUE CODE Copyright 2000, LEXIS Law Publishing, a division of Reed Elsevier Inc. All rights reserved. *** CURRENT THROUGH P.L. 107-7, APPROVED 4/12 ...
Impact of death-tax elimination on appraisers
The last couple of years have seen a continuing (and increasing) discussion about the elimination of the federal estate and gift tax, otherwise known as the death tax. Many businesses are at least p ...
IRS proposes new rules for reporting gifts; Statute of limitations welcome, but some proposed requirements difficult
Certainly taxpayers welcome the provision of the Taxpayer Relief Act of 1997 that starts a three-year statute of limitations on revaluation when a proper gift tax return is filed, whether any gift tax ...