Cases, Rulings, Regulations

In this 8-minute podcast, Bob Keebler and Jason Early discuss the implications of the Tax Court's decision in Cavallaro v. Commissioner, T.C. Memo 2019-144 (10/24/2019). The Tax Court's Memorandum Opinion can be found at https://ustaxcourt.gov/UstcInOp/OpinionViewer.aspx?ID=12088 . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In this 18-minute podcast Bob Keebler interviews attorneys David A. O'Neil and Anna Moody, who represented the taxpayer in North Carolina Department of Revenue v. The Kimberley Rice Kaestner 1992 Family Trust, decided by the United States Supreme Court on June 21, 2019. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In this four-minute podcast, Bob Keebler and Professor Mitchell Gans discuss the implications of North Carolina Department of Revenue v. The Kimberley Rice Kaestner 1992 Family Trust, scheduled for oral argument before the United States Supreme Court this month. They suggest that certain taxpayers in North Carolina and states with similar laws consider filing claims for refund of income tax paid. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In Avrahami v. Commissioner, 149 T.C. No. 7, the Tax Court held that amounts paid to a captive insurance company and an offshore reinsurer were not insurance premiums for federal income tax purposes and were not deductible under Internal Revenue Code section 162. Bob Keebler and Jay Adkisson discuss the decision and its implications. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In this podcast, Bob Keebler discusses the implications of Rev. Proc. 2017-34, creating a simplified procedure to obtain an extension of time to file a portability election. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler and Jonathan Blattmachr This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In CCA 201651013, the IRS Chief Counsel concludes that a trust is not entitled to claim a charitable income tax deduction despite a modification of the trust to permit charitable distributions. Bob Keebler reports. The full text of CCA 201651013 can be found at https://www.irs.gov/pub/irs-wd/201651013.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Rev. Proc. 2016-49 opens new opportunities in planning for the marital deduction. In this podcast, Bob Keebler discusses the available strategies for maximizing estate tax exemptions, protecting assets and preserving flexibility. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In Estate of Barbara M. Purdue et al. v. Commissioner, T.C. Memo. 2015-249 (December 28, 2015), Tax Court Judge Goeke ruled favorably on the estate and gift tax aspects of a family limited liability company. In this podcast, Bob Keebler discusses the case and its implications for estate planning and administration with N. Todd Angkatavanich and James I. Dougherty. For a written analysis of the Purdue case, see LISI Estate Planning Newsletter #2374 (January 11, 2016). This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In this podcast, Bob Keebler and Todd Angkatavanich discuss the basics of Internal Revenue Code section 2701, including: - How section 2701 relates to the rest of Chapter 14 - Application of the section to a broad scope of transactions - The "vertical slice" rule - Recapitalizations and CCA 201442053 - Planning opportunities. Recorded August 25, 2015. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In PLR 201539021, the IRS granted an extension of time for an estate to claim portability. Michelle Ward reports. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

It is widely expected that the Treasury Department will, within the next few months, issue regulations under Code section 2704(b) limiting the ability to claim valuation discounts on transfers of interests in limited partnerships and other entities. In this podcast, Bob Keebler interviews Jonathan Blattmachr, who explains section 2704 and the existing regulations and case law and discusses the potential impact of new regulations. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In Estate of Elkins v. Commissioner (9/15/2014), the Fifth Circuit Court of Appeals upheld a 45% valuation discount for fractional interests in works of art, reversing a decision of the United States Tax Court. In this podcast, Bob Keebler and Jonathan Blattmachr discuss the case and its implications for planning. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler interviews Edwin Morrow of Key Bank and Ohio attorney Bo Loeffler in an in-depth discussion of the implications of the U.S. Supreme Court decision in Clark v. Rameker for asset protection planning and income tax planning for IRAs. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler interviews Professor Mitchell M. Gans and Jonathan G. Blattmachr on the subject of the U.S. Tax Court's decision in Estate of Trombetta v. Commissioner, T.C. Memo. 2013-234. In Trombetta, the Tax Court held that rental properties transferred to an annuity trust were required to be included in the transferor's gross estate because the transfers to the trust were not bona fide sales for adequate and full consideration, and the transferor retained during her lifetime an interest in the transferred properties. Blattmachr and Gans have written an article on the case for the May, 2014 issue of the Journal of Taxation. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

The IRS has just released PLRs 201410001 through 201410010, approving a Nevada Incomplete Nongrantor (NING) Trust. In this podcast, Bob Keebler interviews Bill Lipkind, the attorney who obtained the ruling, and Steve Oshins, the attorney who handled the Nevada state law review. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In Chief Counsel Advice Memorandum 201330033, the IRS concluded that a SCIN transaction by a taxpayer in poor health resulted in a taxable gift. Bob Keebler reports. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler and Mitchell Kitces discuss the very important Section 1035 Ruling. This is a really terrific and very practical interview you will not want to miss. Even if you don't ordinarily listen to PodCasts, listen to this one! This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob Keebler and George Karibjanian follow up on George's recent LISI commentaries on the impact of Windsor. Is it Equality for All or Only for Some? To understand the impact of Section 3 of DOMA, listen to this fascinating discussion. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Bob interviews attorney Michael Goller who discusses the new Covered Opinion Proposed Regulations. This is a very important development focusing on Section 10.37 - dealing with tax opinions and how attorneys must comply. Also stressed in this interview is section 10.35, which requires competence and 10.36 dealing with management oversight proceedures and standards. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com