A Priori Probability

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A Priori Probability

In statistics, the use of logic to estimate the probability of an event. For example, when considering a company's earnings, the company can make a profit, suffer a loss, or break even in a given year. All other things being equal, there is a 1/3 a priori probability of each scenario occurring.
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For this reason, power of appointment trusts are often avoided in second-marriage situations, if there are children from a prior marriage, or if the client is unwilling to give the spouse control over a substantial part of the estate.
121 on a prior sale or exchange of property in the last two years.
1.1503-2(d)(3)(i)(B) confirms this concept, stating that a parent's basis in a member's stock is not reduced in a subsequent tax year as a result of the consolidated group absorbing a DCL carried forward from a prior year (i.e., basis is not reduced twice by the same DCL).
99-5 also provides that the holding period of A's interest will include the holding period of the assets to A prior to the conversion; B's holding period will begin on the date following the date of purchase of the assets.
1.691(a)-1, such property consists of income items that the decedent was entitled to receive at death, but which were not properly includible in his taxable income for the tax year ending with the date of death or a prior tax year under his method of accounting.
453(d), there would be no IRD, because the entire gain would have already been reported by the decedent on his income tax return for the current or a prior tax year.
The IRS found it significant that none of the 32 grandchildren and great-grandchildren ever exercised any withdrawal rights and inferred that the contingent beneficiaries had reached a prior understanding with the donor that the withdrawal rights would not be exercised.(14) Consequently, naming the grandchildren as beneficiaries lacked economic substance and was motivated purely to reduce transfer taxes.
101{a}(2)(A} and (B} will remove the "transfer-for-value" taint from a prior transfer.