Wandry v. Commissioner In certain cases, formula-driven, gift-giving plans have proved to be successful. In other cases, they have not. What characteristics differentiate a formula gift-giving plan that can withstand the Internal Revenue Service (the “service”) scrutiny and be upheld in Tax Court from a plan that gets defeated? The Wandry decision1 provides insight into these questions and highlights issues that taxpayers and tax advisers should consider when structuring and implementing a gift-giving plan. This discussion summarizes: (1) the facts of the Wandry case; (2) the service’s arguments; and (3) the Tax Court decision.
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Annie Cushing is on a Mission to Rid the World of Ugly Data. Learn About Data Collection, Analytics, Technical SEO, Analysis, and Beautification. Annie Cushing, a Senior SEO at SEER Interactive, a Philadelphia-based online marketing agency, explains that “There comes a time in a marketer’s life when making pretty charts with a predefined dataset just doesn’t cut it. “And finding the sum and average of a column of data just doesn’t satisfy you anymore. Eventually — and it’s really inevitable — you will actually have to dive deep into the data and cull out a smaller dataset or manipulate it…