Tax Court Scolds IRS for Talking Out of Many Mouths But Rules in Their Favor

In a recent Tax Court Memorandum opinion, the Court was not too pleased with the operations and the administrative proceedings of the IRS involving Notices of Deficiency issued to a taxpayer. The taxpayer represented himself and was subjected to a confusing series of communications with the IRS causing the Court to sympathize with the taxpayer in…
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My Favorite Presentation from Heckerling

I was fortunate enough to attend the 54th annual Heckerling Institute on Estate Planning in Orlando. Heckerling is known worldwide for being one of the most innovative and informative estate planning conferences put on. The topics are always relevant and timely, and there are always some new and innovative planning techniques and ideas presented. Additionally,…
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The Secure Act: Changes to the RMD Rules of Inherited Retirement Accounts

On December 20, 2019, President Donald Trump signed the Setting Every Community Up for Retirement (Secure) Act into law as part of the year-end spending bill. The Secure Act (the “Act”) goes into effect on January 1, 2020 and makes a host of changes to retirement plan laws. Among these changes are significant changes to…
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Democratic Presidential Candidates: Tax Plans

As the race for the Democratic nomination for President heats up and the first primary election taking place in just 3 months, candidates have begun to release more details about their proposed tax plans.  While these proposed plans will undoubtedly evolve and change over time and are of course subject to being passed by Congress,…
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All about that basis, about that basis, no gains

The Tax Cut and Jobs Act (“TCJA”) enacted some sweeping changes to our nation’s tax laws. One major change was the modification of Section 2010 to increase in the individual estate tax exemption from $5M, indexed for inflation ($5.49M in 2017), to $10M, indexed for inflation ($11.2M in 2018, 11.4M in 2019). Thus couples went…
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The Sale of a Business – Part 5: The Closing

One of the more common engagements for our firm is to assist with business sales and acquisitions. This article is the fifth in a series of articles which will walk through and generally discuss the steps typically associated with the sale of a business. In Part 1, we discussed the breakdown of the business, the…
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Equity as Compensation: The Ins and Outs of the Section 83(b) Election

A common form of compensation for  management and executive level employees is a grant of equity in the employer company, or the option to purchase such equity at a reduced price. Compensation in the form of equity can be a big incentive for employees to join a new company, particularly a startup, or stay at…
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Tax Court Allows Rollover Contribution Past Deadline

In a recent Memorandum opinion issued by the Tax Court, the Court held that the 60-day time limit for individual retirement account (“IRA”) rollovers was met for a distribution and subsequent recontribution of IRA funds despite the funds not being credited back to the IRA upon recontribution until 62 days after the initial distribution. The IRS…
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Recent Celebrity Estate Planning Blunders

This week, I have decided to take a break from our normal more technical writing and discuss some recent celebrity estate planning blunders that have come to light. Not only are these cases interesting and entertaining, but they also can provide valuable lessons when it comes to estate planning. In a previous article, I wrote…
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