Estate Tax Issues
Basis

Effects of the Build Back Better Act on Estates and Trusts

Examining the Effects of the Build Back Better Act on Estates and Trusts On September 13, 2021, the House Ways and Means Committee released the legislative text of proposed tax changes to be incorporated into the omnibus reconciliation bill known as the “Build Back Better Act.”  One wonders if the geniuses behind the BBBA intended the acronym to be pronounced as “Bubba,” but one thing is sure—having now read BBBA as “Bubba” you will never

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Scott St. Amand September 20, 2021
Income Tax Issues
Abusive Tax Shelters

Ryder & Associates Inc. v. Commissioner
T.C. Memo. 2021-88

On July 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Ryder & Associates Inc. v. Commissioner (T.C. Memo. 2021-88). The primary issues presented in Ryder & Associates Inc. v. Commissioner were whether the petitioners received unreported gross receipts from their company, and whether the petitioners had significant unreported dividend income. Author’s Note on Ryder & Associates v. Commissioner As I mentioned earlier this year, I have never seen it bode well for

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Scott St. Amand July 29, 2021
Business Related Issues
Alimony

Schroeder v. Commissioner
T.C. Memo. 2020-117

On August 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Schroeder v. Commissioner (T.C. Memo. 2020-117). The primary issue before the court in Schroeder was whether payments that petitioner-husband made to his petitioner-ex-wife and his divorce lawyer had the effect of increasing the basis in an LLC indirectly owned by petitioner-husband. Background to Schroeder v. Commissioner Petitioner-husband (PH) founded the partnership DCA, LLC in 2003. In 2008, PH assigned his

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Scott St. Amand August 5, 2020
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Effects of the Build Back Better Act on Estates and Trusts

Examining the Effects of the Build Back Better Act on Estates and Trusts On September 13, 2021, the House Ways and Means Committee released the legislative text of proposed tax changes to be incorporated into the omnibus reconciliation bill known as the “Build Back Better Act.”  One wonders if the

Read More »
Scott St. Amand September 20, 2021

Ryder & Associates Inc. v. Commissioner
T.C. Memo. 2021-88

On July 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Ryder & Associates Inc. v. Commissioner (T.C. Memo. 2021-88). The primary issues presented in Ryder & Associates Inc. v. Commissioner were whether the petitioners received unreported gross receipts from their company, and whether the petitioners had significant

Read More »
Scott St. Amand July 29, 2021

Schroeder v. Commissioner
T.C. Memo. 2020-117

On August 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Schroeder v. Commissioner (T.C. Memo. 2020-117). The primary issue before the court in Schroeder was whether payments that petitioner-husband made to his petitioner-ex-wife and his divorce lawyer had the effect of increasing the basis in

Read More »
Scott St. Amand August 5, 2020