On March 27, 2019, Chuck Grassley (R-Iowa) and Ron Wyden (D-Ore.) announced an investigation into potentially abusive syndicated conservation transactions. Senator Grassley commented on the investigation saying: ““There are very legitimate purposes for the conservation easement provisions of the tax code. But when a handful of individuals cook up a scheme to cash in at the…
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The Ninth Circuit recently upheld a 2016 Tax Court case that the charitable deduction for estate taxes was limited to the post-death value of the property actually received by the charity rather than the value of such property that was included in the decedent’s gross estate. Following its decision in Ahmanson Foundation v. U.S., 674…
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One of the more common engagements for our firm is to assist with business sales and acquisitions. This article is the third 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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In the recent Tax Court opinion, Campbell v. Commissioner, T.C. Memo 2019-4, the Court held that assets in a self-settled offshore asset protection trust were not includable in assets collectible by the IRS to satisfy the taxpayer’s assessed income tax liabilities. The case involved John Campbell’s request for an Offer in Compromise, offering $12,603 to…
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At our firm, we use a host of technological tools. As the attorney responsible for research, acquiring, and implementing our tools, I am required to invest a tremendous amount of time in our tools. This article changes pace a bit and may be geared to a different audience, our peers, in hopes to engage in…
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The Mississippi House of Representatives is currently considering a pair of bills that could have a major impact on trust and estates in Mississippi. The bills, H.B. 1375 and H.B. 1425, are the product of a study committee formed by the Secretary of State and touch on a broad range of subjects, including non-probate transfers, transfer…
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One of the more common engagements for our firm is to assist with business sales and acquisitions. This article is the second 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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Whenever I attend a large conference, I try to take some time afterwards to consider the most important takeaways. Having just returned from the 53rd Annual Heckerling Institute of Estate Planning which was held from January 14-19, 2019, I spent the last week reviewing the conference materials and my notes. From this, I have compiled…
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One of the more common engagements for our firm is to assist with business sales and acquisitions. This article is part of a series of articles which will walk through and discuss the steps typically associated with the sale of a business. This series of articles will discuss the process and means of selling a…
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The federal government shutdown is stretching into week four, and there is no end in sight. The shutdown has affected all federal agencies and courts, including the United States Tax Court. One question raised by the shutdown is what effect does it have on Tax Court filing deadlines? The question is important because statutory filing…
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