Income Taxes

When Bad IRA Rollovers Happen to Good People

As we approach the Congressional midterm elections (still with no action on the estate tax), one often hears opinions in certain quarters that the government isn’t efficient. Studiously expressing no opinion about these claims generally, KYEstates is pleased to report that they’re untrue in at least one respect: the IRS has become very efficient at […]

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Variable Prepaid Forwards – Hedge At Your Own Risk…

At KYEstates, we’re happiest reporting on taxpayer victories, but if we have to report a loss, it mitigates our disappointment when the case is interesting. Anschutz v. Comm’r, 135 T.C. No. 5 (July 22, 2010), is that sort of case: an interesting taxpayer loss.  In this instance, a very expensive taxpayer loss (likely exceeding $21 […]

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The Tax Man Likes Home Additions, But Not Tear-Downs

Anyone who has been following Elena Kagan’s confirmation hearings is up to speed on the judicial activism/strict construction debate. Strict construction of an exclusion from taxable income powered a notable win for the IRS in Gates v. Comm’r, 135 T.C. 1 (July 1, 2010), a very interesting income tax case that will have implications for private […]

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What Will Happen to Your Income Taxes in 2011?

On the estate tax front, it’s been a Macbeth/Faulkner fortnight in Congress – full of sound and fury, signifying nothing. Meanwhile, however, the clock is also ticking on expiration of the 2001 and 2003 Bush tax cuts, potentially affecting many private clients and business owners. To that end, readers may be quite interested in the […]

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“Pension Asset Transfer” Life Insurance Strategy Nixed By Tax Court

Although normal activity in much of Louisville seems to be temporarily suspended this weekend due to one of the most impressive logistical enterprises since the Berlin Airlift, the children’s swimming City Meet, the T&E Community still needs tax updates, and KYEstates is happy to share this report on Matthies v. Comm’r, 134 T.C. No. 6 (Feb. 22, 2010). In Matthies, […]

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IRS Notice 2010-32 Allows Full Deduction of Bundled Fiduciary Fees on 2009 Returns

Good news, T&E Community, particularly for fiduciaries: 2009 investment advisory fees charged to nongrantor trusts or to estates continue to be fully deductible without regard to the two percent floor under section 67(a) of the Code. IRS Notice 2010-32 extends the interim guidance provided in Notice 2008-116 and Notice 2008-32 regarding investment advisory costs subject to the […]

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Mr. Filburn, Meet Mr. Attlee – Taxes, The Health Care Bill, and You

Unless you are a truly basketball-crazed KYEstates reader, by now you are well aware that the Health Care Bill passed the House last night.  This legislation is significant, and that is an understatement. Both supporters and detractors of the bill might see this as America’s analogue to July 5, 1948, when the Attlee Cabinet’s National […]

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Letter Ruling Provides Guidance on Inherited IRAs

KYEstates brings you PLR 200945011 (Nov. 6, 2009), a Letter Ruling that KYEstates can’t quite bring itself to really love, even though Natalie Choate surely does.  The Letter Ruling has both good news and bad news for taxpayers.  First, the good news: under the facts of the Letter Ruling, lump-sum, immediate income in respect of […]

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