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Estate Tax Tax Court Tax Liability

Estate taxes, also known as inheritance or death taxes, are taxes on an individual's right to transfer property at death.
Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Warner Norcross + Judd

The Powers and Perils of Intrafamily Loans

It is not uncommon for family members to lend a helping hand to one another through intrafamily loans. While loans can benefit family borrowers who may not qualify for a traditional loan or who need flexible payment...more

Rivkin Radler LLP

“Hey Mom, Can I Have A Few Bucks?” Is It A Loan? A Gift? A Little of Each?

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A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more

Fleurinord Law PLLC

The IRS Estate Tax Battle Over Michael Jackson’s Legacy

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When the King of Pop passed away in 2009, he left behind more than just a rich legacy of music and pop culture. He also left behind a colossal estate that soon became entangled in one of the most scrutinized, drawn-out...more

Gray Reed

The Fine Print: IRS Examination of Artwork

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Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased focus on auditing...more

Lerch, Early & Brewer

IRS Levy Allowed on Classic Italian Cello to Satisfy Outstanding Estate Tax Liabilities

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United States v. Firestone - In United States v. Firestone, the United States (Government or U.S.) sought to enforce a judgment against Defendant Omar Firestone (Omar) for outstanding tax liabilities related to the Estate of...more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

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Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more

Freeman Law

Tax Court in Brief | Estate of Spizzirri v. Commissioner | Gifts, Bequests, Deductible Expenses, and Estate Tax

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Short Summary. Decedent was a wealthy lawyer and investor. During the last few years of his life, decedent paid significant sums to one of his daughters, one of his stepdaughters, and multiple women with whom he was either...more

Freeman Law

Tax Court in Brief | Estate of Kalikow v. Comm’r | Estate Tax Taxation and Deductions and QTIP Trust

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Summary: Pearl B. Kalikow’s  (“Pearl”) husband died in 1990.  On January 4, 2006, Pearl passed away. The SK Trust (“Trust”) was created with the remainder of Pearl’s husband’s estate. On Pearl’s husband will it was instructed...more

Rivkin Radler LLP

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

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Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

Freeman Law

The King of Pop, Michael Jackson’s, Estate Wins Big at Tax Court

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Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge—an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael...more

Bowditch & Dewey

A “Thriller” in Tax Court: The Estate of Michael Jackson and IRS Dispute Valuation of Pop Star’s Image

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How much were the late King of Pop’s name and image worth when he died? His estate put the figure at $2,105 but the IRS believes the value is at least $434 million. That’s a huge discrepancy and with penalties and interest...more

Proskauer Rose LLP

Wealth Management Update - December 2016

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December Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The December § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more

Stinson LLP

Tax Liability for Net, Net Gifts

Stinson LLP on

In Steinberg v. Commissioner, 145 T.C. No. 7 (September 16, 2015), an 89 year old donor made a $109 million taxable gift to her four daughters. The gift was made after the donor and the daughters entered into a gifting...more

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