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LTR 201303006 – Service grants estates of husband and wife extensions to...
Facts. The Taxpayers, Husband and Wife, requested extensions of time under § 2642(g)(1) and Treas. Reg. § 301.9100-1, -3 to allocate GST exemptions to three trusts. Taxpayers created three irrevocable...
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IRS Makes Clear The Substance-Over-Form Doctrine Is A Tool Available Only To...
In response to a September 16, 2012 letter by a taxpayer to the IRS requesting advice regarding whether a taxpayer can exploit the substance-over-form doctrine to recast a transaction, the IRS stated...
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Deutsche Bank Broker Sentenced
By Ruben Conitzer David Parse, a former CPA and broker at Deutsche Bank, was sentenced in federal court to forty-two months in prison for tax obstruction and mail fraud. The Department of Justice...
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