The IRS later acquiesced in Eisenberg (see IRB 1999-4, 4); it agreed that the FMV can be reduced, for estate or gift tax purposes, by the potential capital gains tax liability
The facts of the ruling were designed with the hope that a favorable ruling would apply to numerous similarly situated lenders and borrowers and would enable them to arrange a restructuring without fear of phantom gains tax liability
Even though the practice of voluntarily overreporting a tax liability
and submitting a correspondingly higher tax remittance to offset liabilities that were underreported in earlier filed GST returns is not technically correct under the Excise Tax Act, the practice does not amount to intentional, reckless, or wilful conduct or "indifference as to whether the Act is complied with" within the meaning of "culpable conduct" as contemplated by the legislation.
Asserting that he had no knowledge of the tax liability
when he distributed the estate's assets, Little petitioned the Tax Court for relief.
6402, files a suit against the requesting spouse for the collection of the joint tax liability
, or files a claim in a court proceeding in which the requesting spouse is a party or which involves a requesting spouse's property.
TEI submits that a penalty imposed on individual employees for an improper reduction in the corporate tax liability
simply misses the mark.
His only asset is his retirement account, and the funds in the account are sufficient to pay his tax liability
Further, the willing buyer-willing seller test mandated discounting the IRAs for (1) the income tax liability
associated with their distributions and (2) their lack of marketability.
In other words, the nonresident may end up with a greater tax liability
than a resident because an alimony deduction is denied.