1999 Articles

Adequate disclosure on gift tax return to gain section 6501 statute of limitations protection By David R. Reid June 1999 For all gifts or nongifts (completed transfers of property) made after August 5, 1997, it is important that the gift tax return adequately discloses the gift in order for the taxpayer to be afforded section 6501 statute of limitation protection.

The chairman’s corner By Robert Weber June 1999 This will be my last letter as chairman of the council. By the time this is printed, my term will have expired.

The chairman’s corner By Robert Weber April 1999 The IRS has now been operating under Commissioner Rossotti since November of 1997.

The chairman’s corner By Robert Weber February 1999 As I promised in our first newsletter, I wanted to have interesting speakers at our meetings. So far we have been very successful.

Corporate and partnership tax update August, 1999 By Michael L. English September 1999 In Craven v. U. S., 83 AFTR 2nd Par. 99-526, a Georgia District Court ruled that a stock redemption incident to a divorce was tax free under Code Section 1041.

Corporate and partnership update By John B. Truskowski June 1999 When an employer files for bankruptcy, it may eventually be discharged from its obligations to remit taxes it withheld from wages paid to its employees.

Corporate and partnership update By John B. Truskowski February 1999 In 330 W. Hubbard Restaurant Corporation, d/b/a Coco Pazzo v. United States, N.D. Ill. No. 98 C 178, District Court Judge Marvin Aspen held that a restaurant was liable for FICA taxes on unreported tips.

Editor’s note By Michael L. English November 1999 At the September 24, 1999, meeting of the Federal Taxation Section Council, the members of the council heard a guest presentation by Edith Siler, Senior Attorney with the Office of IRS District Counsel, in Chicago.

Estate and gift tax update By Alfred Sanders June 1999 In the past when multiple interests in the same asset have been included in a decedent's gross estate the multiple interests have been aggregated in order to determine their value.

Income tax treatment of state and federal grants By Don Johnson November 1999 Various state and federal agencies make grants of funds to both public and private corporations for economic development, improvement of public facilities and related purposes.

Individual income tax update By James S. Zmuda September 1999 Several requirements must be satisfied for divorce related payments to be treated as alimony, taxable to the payee and deductible by the payor.

Individual income tax update By Carlos A. Saavedra June 1999 Most individual taxpayers that are homeowners can itemize deductions due to the deductions for real estate taxes and home mortgage interest.

Individual income tax updates By Carlos A. Saavedra February 1999 For quite a number of years, the IRS' standard mileage rate for automobile business use generally increased slightly from one year to the next.

Individual income tax updates: IRS issues new guidance for innocent spouse relief By Thomas F. Arends April 1999 The Internal Revenue Service has issued new interim guidance for taxpayers seeking equitable relief under the innocent spouse provisions enacted under new Internal Revenue Code section 6015 of the IRS Restructuring and Reform Act of 1998 ('98 Act).

Message from the chair By George E. Marifian November 1999 In the last issue, we commented on the flurry of tax proposals being debated in Congress before the Labor Day Recess.

Message from the chair By George E. Marifian September 1999 Greetings and welcome to the new fiscal year for our section. I am pleased to report that we began the year with an excellent council meeting at Lake Geneva in June.

Of FLPs and LLCs: Alternative estate freeze and asset protection techniques By James S. Zmuda February 1999 The estate planning world has become filled with acronyms, including: GRITs, GRATs, GRUTs, NIMCRUTs, QPRTs, FLPs and LLCs.

Partnerships and the new capital gain rules—new guidance from the IRS By Edward J. Hannon November 1999 In August, the IRS issued two proposed regulations that provide guidance on some of the previously unresolved issues facing partnerships and limited liability companies.

Procedure update By Carlos A. Saavedra November 1999 Code section 7122 authorizes the Secretary of the Treasury, and by delegation, IRS, to compromise any civil or criminal case.

Single member limited liability companies – the new year brings new guidance from the IRS By Edward J. Hannon April 1999 In recent years, the concept of having an entity that is disregarded for federal income tax purposes has become a hot topic.

Taxpayers making “voluntary” installment agreement payments cannot designate to which liabilities the payments will apply By James S. Zmuda June 1999 Opportunities to defer or reduce the collection of tax payments by the Internal Revenue Service ("IRS") include bankruptcy1 and offers in compromise.2 Another approach is the installment agreement.

Trade associations, associate members and unrelated business income By David R. Reid April 1999 Business Leagues, Chambers of Commerce, Real Estate Boards, Boards of Trade, or Professional Football Leagues not organized for profit and no part of the net earnings of which inures to the benefit of any private shareholders or individuals are exempt from federal income tax pursuant to IRC section 501(c)(6).