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Pillsbury Winthrop Shaw Pittman LLP

Norwich v. Comm’r: Private Credit Firm Prevails in Tax Dispute to Reverse Over-Reported Income

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In Norwich v. Comm’r, the taxpayer mistakenly received $7.5 million[2] as a result of various bank errors between 2007 and 2014. Not knowing that the cash was incorrectly released to it, the taxpayer reported those amounts as...more

Bressler, Amery & Ross, P.C.

How to Take Advantage of Changes in Interest Rates For Gift and Estate Tax Savings

Bressler, Amery & Ross, P.C. on

A recent Tax Court order highlights the gift and estate planning opportunities afforded when a senior family member makes loans to other family members. In Galli v. Commissioner, Docket Nos. 7003-20 and 7005-20, the Court had...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

Troutman Pepper Locke

When Does a Loan Guarantee Provide Amounts at Risk - Tax Update, Volume 2020, Issue 3

Troutman Pepper Locke on

In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more

Foley & Lardner LLP

401(k)/403(b) Loan Borrowers – Check Your Paystubs!

Foley & Lardner LLP on

A recent tax court case, Louelia Salomon Frias, v. Commissioner, TC Memo 2017-139, illustrates why it is good practice to verify that employee loan repayments have been timely deducted. Plan Loan Requirements. An employer...more

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