The U.S. Court of Appeals for the Second Circuit reversed a New York stockbroker's conviction April 30 on charges of tax evasion for 1996 and 1997 due to insufficient evidence, and vacated her convictions for mail fraud and tax evasion for 1995 on the grounds the counts were improperly joined (UnitedStates v. Litwok, 2d Cir.,…
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Partnership dissolution before death caused assets to be included in estate at full value
Estate of Lois L. Lockett, TC Memo 2012-123 The Tax Court has found that a family limited partnership terminated under state law when one partner, an individual, became the entity's sole owner. As a result, the individual owned 100% of the former entity's assets at her death and they were taxable in her estate at…
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Tax Court Ruled that Permanent Resident's Wages Paid by German Government Not Tax Exempt
The wages of a permanent resident of the United States that were paid by Germany and a foreign government office were not exempt from taxation under the tax code and a North Atlantic Treaty agreement, the U.S. Tax Court held May 1 (Harrison v.Commissioner, T.C., No. 15074-10, 138 T.C. No. 17, 5/1/12). The Tax Court…
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Philip Marris Agrees to Pay $500MM to Resolve LILO and SILO Leasing Transactions
RICHMOND, VA – May 22, 2012 – Altria Group, Inc. (Altria) (NYSE: MO) today announced that it has executed a Closing Agreement (Agreement) with the Internal Revenue Service (IRS) that, subject to court approval, resolves the federal income tax treatment for all prior tax years of certain leveraged lease transactions (referred to by the IRS…
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