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Agostino & Associates – January Tax Newsletter – Civil Forfeiture & Valuation Issues

Frank AgostinoAgostino & Associates' January tax newsletter contains two articles:

    1.  Jeremy Klausner discusses the new IRS policy on civil forfeiture of structured funds. The new IRS policy regarding forfeitures seems to indicate that the government will no longer seek to forfeit legitimate source funds that are involved in structuring. The open questions, however,are how this policy will be interpreted by those tasked to enforce it and what will constitute the so far undefined “exceptional circumstances.”

      2.  Lawrence Sannicandro discusses how to approach valuation issues in tax litigation. Valuation continues to be at the core of many tax disputes, and the strategies for effectively

      litigating valuation cases are rapidly evolving.  Empirical evidence demonstrates that the forum
      where valuation issues are most likely to be litigated, the United States Tax Court (“Tax
      Court”), decided questions of value in approximately 35.1% of its reported opinions in 2014
      and 20.4% of its reported opinions in 2013. These statistics are staggering when viewed in the light of the fact that valuation cases are disproportionately more likely to settle than non-valuation cases.


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        Read more at: Tax Times blog

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