Estate of Skeba (DC NJ Oct. 3, 2019): Estate Entitled to Abatement of Failure to File Penalty for Late Estate Tax Return

The US District Court for the District of New Jersey held that an estate was entitled to a refund of failure to file penalties for filing an estate tax return late. The court reasoned that IRS refusal to abate the penalties was arbitrary and capricious. See full opinion by clicking Estate of Skeba (DC NJ … Continue reading Estate of Skeba (DC NJ Oct. 3, 2019): Estate Entitled to Abatement of Failure to File Penalty for Late Estate Tax Return

Art Crimes and Misdemeanors: Managing Risk in Estate Administration and in Appraisals of Stigmatized Art

By Sarah Moore Johnson, Esq. & Cindy Charleston-Rosenberg, ISA CAPP Misattributed and other forms of stigmatized artwork lurking in important estate collections is far more pervasive than generally appreciated by fiduciaries. If overlooked during the appraisal process, misattributed and unattributed works may result in significant wealth loss through overpayment of tax liability or depressed sale … Continue reading Art Crimes and Misdemeanors: Managing Risk in Estate Administration and in Appraisals of Stigmatized Art

CCA 201939002: Pending Merger to be Considered When Valuing Stock for Gift Tax Purposes (Sep. 30, 2019)

The Office of Chief Counsel issued an advice on whether a hypothetical willing buyer and seller of a publicly-traded company would consider a pending merger when valuing stock for gift tax purposes. The issue and conclusion of the CCA are as follow ISSUEWhether, under the circumstances described below, the hypothetical willing buyer and seller of … Continue reading CCA 201939002: Pending Merger to be Considered When Valuing Stock for Gift Tax Purposes (Sep. 30, 2019)

Widtfeldt v. Commissioner, U.S. Dist. Court, D. Nebraska: Beneficiary Personally Liable for Unpaid Estate + Gift Taxes (Sept. 17, 2019)

In Widtfeldt v. Commissioner, U.S. Dist. Court, D. Nebraska (8:18CV453, September 17, 2019), a beneficiary who received property from his mother by gift and at the mother’s death was personally liable for the unpaid estate and gift tax.  The beneficiary received four parcels of real estate from his mother by gift or at death. Gift … Continue reading Widtfeldt v. Commissioner, U.S. Dist. Court, D. Nebraska: Beneficiary Personally Liable for Unpaid Estate + Gift Taxes (Sept. 17, 2019)

Emerging Issues for the Family Office

From taxation complexity to cyberthreats, what are today’s top concerns? By Randy Abeles, Tax Partner, RSM US LLP Family offices come in all shapes and sizes and the differences from one to another can be vast. And, yet family offices have common challenges—and opportunities—especially in today’s dynamic business environment. From addressing the complexities of taxation … Continue reading Emerging Issues for the Family Office

The Growing Debate Over Elizabeth Warren’s Wealth Tax | The New Yorker

The New Yorker has published an article that examines Elizabeth Warren's proposal for an annual wealth tax. The New Yorker article begins as follows: As Senator Elizabeth Warren prepares for Thursday’s Democratic debate, in Houston, she is the first viable contender for the Presidency in decades to have proposed a direct tax on wealth. In … Continue reading The Growing Debate Over Elizabeth Warren’s Wealth Tax | The New Yorker

Ambrosio, How IRS Guidance Makes it impossible to Comply with Section 2801 in 2 Hours or Less, The Value Examiner, p. 35, Jul-Aug 2019

Fabio Ambrosio, Central Washington University, has made available for download his article, “How IRS Guidance Makes it impossible to Comply with Section 2801 in 2 Hours or Less,” which was published in The Value Examiner, p. 35, Jul-Aug 2019. The Abstract is as follows: In 2008 Congress added Section 2801 to the Internal Revenue Code. This … Continue reading Ambrosio, How IRS Guidance Makes it impossible to Comply with Section 2801 in 2 Hours or Less, The Value Examiner, p. 35, Jul-Aug 2019