This may be the best time to transfer a large amount of wealth without transfer taxes. Unfortunately time is running out on this short term opportunity because the current generous gift-tax exemptions are scheduled to expire at the end of 2012. The lifetime exemption from Federal gift tax has been at its highest level the…
Read more
About: Ronald Marini
Recent Posts by Ronald Marini
Supreme Court Tells IRS 3 Years To Audit Is PLENTY! (Continued)
Home Concrete & Supply, LLC, (Sup Ct4/25/2012) 109 AFTR 2d 2012-661 The Supreme Court, resolving a split among various Circuit Courts and the Tax Court, has determined that an overstatement of basis isn't an omission of gross income for purposes of Code Sec. 6501(e)(1)(A)'s 6-year limitations period. The Court found that the '58 Colony decision,…
Read more
IRS Contemplates Guidance Clarifying Rescission Doctrine, Alexander Says
The Internal Revenue Service continues to contemplate the contents of a possible guidance project to assist taxpayers when applying the rescission doctrine after the Service ruled in January that it will no longer offer additional interpretations of the doctrine, IRS Associate Chief Counsel (Corporate) William D. Alexander said. Currently taxpayers have only a 32- year-old…
Read more
Refund claim, filed by a Ponzi scheme victim, was modification of earlier one and therefore not untimely
In Chief Counsel Advice (CCA) 201216033, IRS has concluded that a Form 843 (Claim for Refund and Request for Abatement) filed by a Ponzi scheme victim was a permissible amendment to her timely filed Form 1040X rather than a new, untimely claim for refund for tax year 2003. Background.Code Sec. 6402 authorizes IRS to make…
Read more
Recent Comments by Ronald Marini
No comments by Ronald Marini yet.
