Trust Beneficiary Engages In Like Kind Exchange Using Trust Property
June 10, 2024 | Louis Vlahos | Estate
Mere Change in Form It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the exchanged property, is treated as realized income or loss. Moreover, the general rule with respect to such realized gain…
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Collecting an Individual’s Unpaid Taxes from Their Controlled Entities
May 29, 2024 | Louis Vlahos | Federal
You Mess With The Bull . . . An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in what…
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Tax Authorities of the World Unite? Not Quite, But the IRS Joins the Movement to Tax the Rich
May 15, 2024 | Louis Vlahos | Federal
“Let’s make sure if they move, they have nowhere else to go because we’re all taxing them together.”[i] Around the Globe Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key…
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Partnership Transactions Lacking Economic Substance or Business Purpose: Investor Beware
May 03, 2024 | Louis Vlahos | Business
Sale, or Contribution-Distribution? Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than his adjusted…
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Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?
April 23, 2024 | Louis Vlahos | Federal | Income Tax
Notice of Deficiency Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being notified that the IRS has determined…
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IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability
April 18, 2024 | Louis Vlahos | Federal
Use Your Imagination Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the levy, arguing they had already paid the tax. The IRS Office…
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An Inveterate Golfer At the IRS
April 10, 2024 | Louis Vlahos | Federal | Income Tax
Tax Season As we approach the deadline for paying federal individual income taxes and, generally, for filing the returns on which such taxes are determined, some of you may be recalling how the Inflation Reduction Act of 2022 appropriated billions of dollars[i] to the IRS to bolster enforcement of the…
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Trust Fund Recovery Penalty & The Closely Held Business
April 03, 2024 | Louis Vlahos | Business
It’s Still Pretty Bad Depending upon what you read or, perhaps more accurately, depending upon how much you believe of what you read, you may be aware that many closely held businesses are concerned about their future. Most of these survived the disruption caused by the pandemic lockdown only to…
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“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*
March 25, 2024 | Louis Vlahos | Business
Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate.[i] Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.[ii] Perhaps the Senator was inspired by the Administration’s Fiscal Year 2025 Budget, which includes its own equally ill-fated –…
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Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?
March 15, 2024 | Louis Vlahos | Federal Budget
The Budget is Here![i] Earlier this week the White House released its Fiscal Year 2025 Budget.[ii] Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The release of the budget comes four…
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