Singer v. Comm’r, T.C. Memo. 2016-48 At the time of his death, Melvin Sacks was legally married to Alvia Sacks but had been estranged from her for 25 years. His “longtime companion” was Lucille Atwell, with whom he jointly owned a brokerage account worth some $2 million. Atwell was the beneficiary of Sacks’ life insurance…
Month: June 2016
Settlement of gift tax dispute does not waive interest due on unpaid taxes.
Estate of Anthony La Sala v. Comm’r, T.C. Memo. 2016-42 When he was 93, Anthony La Sala created ALS Family LLC to own and manage his wealth. He sold a 99% interest in the company to his daughter when he was 95 for a lifetime annuity of $913,986. In the exchange, the retained 1% was…
Failure to report a taxable gift does not create a cascade of problems in subsequent gift tax re-turns.
ECC 201614036 Taxpayer made a substantial taxable gift in Year 1, but never filed a gift tax return. The IRS can assess a gift tax at any time, in any subsequent year, because the statute of limitations never begins to run. Sumner Redstone recently learned this lesson the hard way, when he had to pay…
The IRS attempts to measure the "tax gap"
For the first time in ten years, the IRS has attempted to measure the “tax gap,” the difference between what taxpayers are paying and what they should be paying under the tax law. The gap hasn’t changed much over the years, according to information from IRS Commissioner Koskinen at an April press conference. The net…
Charities Helping Americans Regularly Throughout the Year (CHARITY) Act
To the applause of the nonprofit community, Senate Finance Committee member John Thune (R-S.D.), and Committee ranking minority member Ron Wyden (D-Ore.), in April introduced Charities Helping Americans Regularly Throughout the Year (CHARITY) Act (S. 2750). Important elements of the bill include: allowing donor-advised funds to receive charitable IRA distributions; simplifying the standard mileage rate…
Health care reform task force
In February House Speaker Paul Ryan (R-Wisc.) appointed six task forces to study health care reform and ways to make the tax code reward work better. An early report was released April 29. Targets include eliminating the marriage tax penalty and bringing down the corporate tax rate, which is among the highest in the developed…
Sensible Estate Tax Act of 2016
Democrats on the Ways and Means Committee are supporting H.R. 4996, the “Sensible Estate Tax Act of 2016,” introduced by ranking minority member Sander M. Levin (D-Mich). Key elements of the bill include: reducing the federal estate tax exempt amount to $3.5 million; chopping the federal gift tax lifetime exemption to $1 million; capping the…