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IRS Notice Response Tips Everyone Should Know

Knowing what to do when your client receives a notice from the Internal Revenue Service can be a useful skill.  Here are 13 pointers, from what to do when the IRS sends a notice of deficiency to whether to extend the statute of limitation. To read the full article in The Tax Adviser, click: IRS Notice Response Tips Everyone Should Know. ...

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Estate of Woelbing

Settlement of a Valuation Case Before the U.S. Tax Court This article discusses issues found in a case that is pending before the United States Tax Court (the “Tax Court”).  The specific issues relate to issues regarding sales of closely held stock to grantor trusts in exchange for promissory notes.  Specifically, the IRS took issue with two grantor sale trust transactions.  The two cases were filed on Dece ...

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Delaware LLC Operating Agreement Sets Forth the Ownership Interest

Failure to make capital contributions did not void the operating agreement or reduce the ownership interest of non-complying partners In Grove v Brown, the Delaware Court of Chancery, relying on the unambiguous terms of a limited liability company (LLC) operating agreement, found that a member’s failure to make an initial capital contribution to a LLC did not affect that member’s ownership interest.   Furth ...

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