Charitable Issues

Nonqualified Disclaimers to a Charity as a Planning Technique

After your exceedingly long discussion with Uncle Bill a few weeks ago regarding his FBAR filing requirements, there has been total radio silence between you and Bill—not that you mind it in the least bit. The first day of fall came and went, but apparently no one told Florida. It was 85° outside on September 22nd, and though a discolored oak leaf fell onto the hood of your car, you suspected that it was the

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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 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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Valuing a Complex Legacy: Lessons in Valuation From Estate of Jackson

My second article, published in Bloomberg Tax is entitled “Valuing a Complex Legacy: Lessons in Valuation from Estate of Jackson.”  It was published in Bloomberg’s Estates, Gifts, and Trusts Journal (46 Tax Mgmt. Est. Gifts Tr. J. No 5 (Sept. 9, 2021)). The article was written in response to the inestimable Judge Mark Holmes’ opinion in Estate of Jackson v. Commissioner, T.C. Memo. 2021-48, a 271 page leviathan of an opinion regarding the trials and tribulations in the

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McCrory v. Commissioner (T.C. Memo. 2021-116)

On October 4, 2021, the Tax Court issued a Memorandum Opinion in the case of McCrory v. Commissioner (T.C. Memo. 2021-116). The primary issue presented in McCrory was whether the IRS Whistleblower Office’s rejections of the petitioner’s claims were unsupported by the administrative record and were arbitrary, capricious, an abuse

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Gregory v. Commissioner (T.C. Memo. 2021-115)

On September 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Gregory v. Commissioner (T.C. Memo. 2021-115). The primary issue presented in Gregory was whether the claimed deductions permitted under IRC § 183(b) for activities not engaged in for profit are not subject to the 2%

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A Primer on Employment Tax Withholding

When the IRS is involved, monetary transactions are never as simple as they appear on the surface. The late, great comedian Mitch Hedberg once told a story about being given a receipt after buying a doughnut. I bought a doughnut, and they gave me a receipt for the doughnut. I

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Clark v. Commissioner (T.C. Memo. 2021-114)

On September 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Clark v. Commissioner (T.C. Memo. 2021-114). The primary issue presented in Clark was whether the petitioner fraudulently underreported his income. Held:  Oh, dear God.  The fraud! The Tax Court’s Summary of the Issue in Clark

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Whistleblower 14377-16W v. Commissioner (T.C. Memo. 2021-113)

On September 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 14377-16W v. Commissioner (T.C. Memo. 2021-113). The primary issues presented in Whistleblower 14377-16W were whether the whistleblower could proceed anonymously, and whether the WBO abused its discretion in denying the whistleblower-petitioner an award. Held:

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Brown v. Commissioner (T.C. Memo. 2021-112)

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Brown v. Commissioner (T.C. Memo. 2021-112). The sole issue presented in Brown was whether the Tax Court has jurisdiction to order the refund of a TIPRA payment. What is a TIPRA Payment? The Tax Increase

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