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Fourth Circuit Affirms Belk

Wednesday, December 17, 2014

In Belk v. Commissioner, the 4th Circuit federal appeals court affirmed a Tax Court decision disallowing a claimed charitable deduction for a "floating" conservation easement, in which the transferors reserved a power to substitute contiguous parcels.

Senate Approves Short-Term Extenders Package, Including IRA Rollover

Wednesday, December 17, 2014


By a vote of 76 to 16, the Senate late yesterday approved H.R. 113-5771 ("Bill"), a package of more than fifty one-year extenders, including the Charitable IRA Rollover and several other charitable deduction measures.

Revocations and Rejections

Tuesday, December 16, 2014

Among this week's release of private letter rulings were four revocations, PLRs 201450020 through 201450023.

President Signs Compromise Bill to Fund the Government

Tuesday, December 16, 2014  Updated!


Late yesterday, the House narrowly passed a $1.1 trillion spending bill ("Bill") to keep the federal government funded through the fiscal year ending September, 2015. The Senate then approved a two-day spending resolution and will consider the House Bill today.

UPDATE (12/13/2014): The Senate passed the House Bill late Saturday night, December 13th, in an unusual weekend session, despite opposition from liberal and conservative groups.

UPDATE (12/16/2014): The President signed the compromise Bill into law.

PLR 201450002 - Late Election to Sever QTIP Trust

Monday, December 15, 2014

In PLR 201450002, the Service exercised its discretion to allow an executor belatedly to sever a testamentary trust into two trusts and to elect to treat only one as QTIP.

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