6330(c)(2)(B) also allows taxpayers to raise "the underlying tax liability
" as an issue at a collection due process hearing if the taxpayer "did not receive any statutory notice of deficiency for such tax liability
or did not otherwise have an opportunity to dispute such tax liability
2004)), which held that the estate should not discount the value of the decedent's retirement account to offset the beneficiary's future tax liability
In Situation 3, Trust's governing instrument states that if G is treated as the owner of any portion of Trust for any tax year, the trustee may, in the trustee's discretion, distribute to G for the tax year income or principal sufficient to satisfy G's personal income tax liability
attributable to including all, or part, of Trust's income in G's taxable income.
The reserve accrual for contingent tax liability
is eliminated, since it is extinguished by the contract.
Instead, the taxpayer may exchange the property for another of like or greater value, thereby deferring the tax liability
AQuoted shares no longer qualify for gift relief and it is likely that you will incur a capital gains tax liability
if you transfer all the shares to your daughter in one tranche.
The agency - a joint venture between Thousand Oaks and the Conejo Recreation and Park District, which controls about 10,000 acres of open space - learned about the tax liability
only when it received a tax bill from Los Angeles County in 1992.
If you are contemplating making a large purchase near year-end in a taxable, nonretirement account and the distribution is significant, you should probably put off the purchase by buying after the record date to avoid incurring an immediate tax liability
However, the Tax Court ruled that the government's interests were not prejudiced, because "granting petitioner an extension of time to file his section 475(f) election does not result in petitioner's having a lower tax liability
than he would have had if he had timely filed the election.
Under the proposed Interpretation, a previously recognized tax position that no longer meets the probable recognition threshold would be derecognized by recognizing an income tax liability
or reducing a deferred tax asset in the period in which the enterprise concludes that it is more likely than not that the position will not be sustained on audit.
The IRS says the rule is consistent with the intent of both the foreign tax credit, which is to avoid double taxation of foreign income, and the foreign tax credit limitation, which was written to prevent foreign tax credits from offsetting tax liability
AMT permits a disallowance of 90 percent of the NOLs, leaving 10 percent of the NOLs as a tax liability