Recent Developments – Tax

Using Political Futures Markets to Forecast Your Estate Tax Exemption

You can tell your readers care about you when for four weeks you don’t post, and they begin to inquire after your health. Thank you, and your publisher is pleased to report that he is alive and very well! This has been a very busy month. No one seems to have gotten the memo that [...]

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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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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 Wins FLP Case: Not All Timber Barons Are Teflon

Although we wish it were otherwise, taxpayers don’t always win FLP cases.  In fairness, the IRS ought to win a case from time to time, given that they’re usually the party making the decision to settle or litigate.  When the facts are as unfavorable to the taxpayer as they were in Estate of Malkin v. [...]

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Substantial Win for “Buy and Hold” FLP – Murphy Oil Heirs Are Smiling (But the IRS Isn’t)

 It’s possible KYEstates readers are focused on the Paul-Grayson Senate race, or the Louisville mayoral race (see latest polls here, and here, respectively). If you want a break from politics, however, we can take you back to the normal state of things (i.e., all transfer taxes, all the time) with a report on a truly resounding taxpayer [...]

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Fisher v. U.S. – Taxpayers Denied Gift Tax Annual Exclusion for Gifts of LLC Interests

We’re never happy to report IRS wins at KYEstates, but if we have to bring you news of taxpayer defeat, we like it when the defeat breaks no new ground in favor of the government. KYEstates previously discussed the denial of the annual exclusion for gifts of limited partnership interests in Price, which was sort of [...]

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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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Announcing the KYEstates Estate Tax Forecasting Contest

KYEstates readers, do you miss the halcyon days of 2003, when Howard Dean told us that “you have the power“? We can’t bring those days back, but we are happy to report that in 2010: You have the power…to let your own voice be heard about what is going to happen with the estate tax. [...]

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