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5th Circuit Reverses Tax Court in Elkins

Thursday, September 18, 2014

In Estate of Elkins v. Commissioner, the 5th Circuit federal appeals court reversed a decision of the Tax Court allowing only a ten percent discount on fractional interests in artworks in a decedent's estate.

Cavallaro: Intra-Family Merger Triggers Gift Tax

Thursday, September 18, 2014


In Cavallaro v. Commissioner, a husband and wife received shares in a merger of a corporation they owned into a corporation owned by their three sons. The Tax Court determined the shares received by the parents were undervalued, resulting in an unreported gift of $29.6 million. The merger occurred almost 20 years ago!

Case Study: Increasing Lifetime Cash Flow For a Life Partner

Thursday, September 18, 2014

By transferring highly appreciated stock to a SCRUT, with the remainder passing to a DAF upon the death of the last surviving partner, a taxpayer is able to increase the lifetime cash flow for himself and his life partner, defer capital gains tax, and make gifts to charities.

October 7520 Rate Flat at 2.2% for Fifth Month

Thursday, September 18, 2014

Rates, Tables & Statistics

In Rev. Rul. 2014-26, the Service announced the Section 7520 rate for October will remain at 2.2% for a fifth consecutive month. The rate has touched 2.4% three times in the past thirteen months. Through the first ten months of this year, the rate is averaging 72 basis points higher than the first ten months of 2013.

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