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Most Recent Posts

High Flying Insurance Agent Could Not Stop IRS Jeopardy With Let’s Make A Deal

High Flying Insurance Agent Could Not Stop IRS Jeopardy With Let’s Make A Deal

When Mr. Brown’s representative had a telephone conference with the IRS settlement officer it was indicated that the only “distrainable asset” was $5 million of equity in the residence.  The plan to pay the IRS off in installments would be based on Mr. Brown obtaining financing in order to buy a pool of insurance policies that would produce a flow of income. He promised further details which came in the form of a 300 page document.

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$16 Million Golf Course Conservation Deduction Disallowed On Fine Points

$16 Million Golf Course Conservation Deduction Disallowed On Fine Points

One of the requirements of a deductible easement donation is that it be in perpetuity.  An implication of that is that the easement has to be superior to any mortgages.  So you have to get the entities holding mortgages to subordinate.  Hillcrest did subordinate, but the subordination was not filed until several months after the easement deed.  Taxpayers argued that there was an oral agreement in place to get the subordination, but that did not cut it.  So no deduction

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Claiming A Conservation Easement Deduction? Use A Tax Attorney

Claiming A Conservation Easement Deduction? Use A Tax Attorney

One of the requirements to make a conservation easement deductible is that the conservation purpose be “protected in perpetuity”. That is a really long time.  And there is recognition that maybe things will change and that in the future people will think that it would be better if we just paved everything.  So there is a kind of out.  If due to unexpected changes the conservation purpose can no longer be fulfilled then there can be a clause that says that the donee organization gets a cut of the proceeds.

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AMT Credit Carryover Dies With The Taxpayer

AMT Credit Carryover Dies With The Taxpayer

The other practical observation from a planning viewpoint is to note many valuable tax attributes even for example basis in excess of value will die with the taxpayer.  There may be planning opportunities that present themselves.  Consider a taxpayer with large charitable carryovers or net operating losses and substantial IRA assets.  It might be worth ending the income deferral while there are attributes to shelter it rather than leaving behind an income tax liability.

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Alert Vanguard Client Service Leads To Intervention In Elder Abuse Case

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The Santa Clara County model differs from other financial abuse prevention teams in that “rapid response” by the team members is a central component. “Immediacy is important to freeze assets and to prevent financial destitution,” says Lee Pullen, Director of the Department of Aging and Adult Services. When APS receives a call through its telephone hotline, APS immediately determines whether the case is appropriate for FAST. A referral to FAST triggers a prompt visit to the elder or dependent adult by at least two members of the team

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