2010 AP Bulletin Archive Page

Legacy of Enron Continues: Treasury Expands Partnership Anti-Abuse Regulations: Treasury Decision 9485 (June 28, 2010)
Inflation and Cost of Living Adjustment Figures for 2011
The IRS Checks Back In With the Incidental Death Benefit Rules: Private Letter Ruling 2010-43-048 (August 3, 2010)
Time is Running Out to Take Advantage of 100% Exclusion of Gain on Sale of Qualified Small Business Stock

Contact Client Now to Share Planning Ideas for Remainder of 2010
Year-End Gifting Strategies
Breaking the Cardinal Rule? Cross-Endorsements as an Alternative Method for Arranging Life Insurance Policies in a Cross-Purchase
The Gift Tax Consequences of Giving Long Term Care Insurance
New Roth 401(k) Rules Provide Limited Benefits

Options for Paying Estate Taxes
Good News for Partial Exchanges and Partial Annuitizations: Private Letter Ruling 2010-38-012 (September 24, 2010); and Section 2113 of the Small Business Jobs Act of 2010
Sticking It to the Taxpayer – Deduction Denied for Interest on Graegin Loan: Stick v. Comm’r, T.C. Memo 2010-192 (September 1, 2010)
IRS Scores a Victory in Family Limited Partnership Valuation Discount Case: Holman, Jr. v. Comm’r, 105 A.F.T.R. 2d 2010-1802 (8th Cir. 2010)
Brief Summaries

Making Gifts and Paying Tax in 2010 – It Really Might Be Worth It
Spendthrift Trust Upheld Despite Beneficiary’s Control of Trust: Miller v. Kesser, __ So. 3d. __, (Fla. Dist. Ct. App.) (May 5, 2010)
Slapped… Then Slapped Again: Seizing IRA Assets for Unpaid Payroll Taxes: Swanton v. Comm’r, T.C. Memo 2010-140 (June 24, 2010)
Creditors Can Charge Through Florida LLCs: Olmstead v. FTC, Case No. SC08-1009 (Fla. 2010)
Discounting Fractional Interests – High School Math Does Come In Handy: Ludwick v. Comm’r, T.C. Memo 2010-104 (May 10, 2010)
Brief Summaries

New Investment Income Tax is Selective About Its Victims
Watch Out for Snakes in the Grass: Tax Apportionment Can Lead to Unintended Consequences: Estate of Sheppard v. Schlies, 2010 WI 32 (May 4, 2010)
Be Careful Where You Step: Pierre v. Commissioner, T.C. Memo 2010-106 (May 13, 2010)
Securities and Exchange Commission as a Creditor: SEC v. Solow, 682 F.Supp.2d 1312 (S. Dist. Fla. 2010)
Brief Summaries

Recharacterization of Roth IRA Conversions: The Truth is Out There
A Checklist to Test if a Welfare Benefit Plan Works: Supreme Court’s Refusal to Hear Appeal of DeAngelis v. Comm’r Provides Opportunity to Review the Many Hurdles for Welfare Benefit Plan Deductions: Supr. Ct. Dkt. 09-895 (March 22, 2010)
No Second Class of Stock: S Corporation May Make Discretionary Distributions Due to Tax Return Adjustments: Private Letter Ruling 2010-17-019 (April 30, 2010)
Brief Summaries

Using Roth IRAs to Help Children Save (from) Themselves
Are Inherited IRAs Protected from the Beneficiary’s Creditors? No…. Wait, Yes…. Maybe? In Re: Chilton, 105 A.F.T.R. 2d 2010-1271 (March 5, 2010); In Re: Nessa, 105 A.F.T.R. 2d 2010-1825 (April 9, 2010)
The Annual Exclusion and Gifts of LLC Interest: The Taxpayer Strikes Out Again: Fisher v. U.S., 105 A.F.T.R. 2d 2010-1347 (March 11, 2010)
Brief Summaries

Getting the Long-Term Care Insurance Deduction for Owner/Employees of S Corporations (and other Self-Employed Taxpayers)
Don’t Play Games When Valuing a Life Insurance Policy: Matthies v. Comm’r, 134 T.C. No. 6, (February 22, 2010)
A Spousal IRA Rollover When a Trust is Named Beneficiary: Too Little Control Equals No Rollover: Private Letter Ruling 2009-44-059 (October 30, 2009)
Once Upon A Time There Was A QTIP Election: Estate of Morgens v. Comm’r, 133 T.C. 17 (December 21, 2009)
Brief Summaries

Ten Ways to Add Flexibility to Irrevocable Life Insurance Trusts
The 10% Early Withdrawal Penalty – Chart Comparing the Exceptions for Qualified Plans, IRAs, and Nonqualified Annuities
Roth Conversions and Life Insurance
Gifts to Grantor Trusts in 2010: Threatened, but Unscathed: Notice 2010-19, 2010-7 I.R.B. (February 2, 2010)
Self-Settled Trust Not Included in Grantor's Estate: Private Letter Ruling 2009-44-002 (October 30, 2009)
When Can a Minor Disclaim? Private Letter Ruling 2010-04-006 (January 29, 2010)
Using Gifts to Maximize an Inheritance
Brief Summaries

Avoiding Estate Inclusion of Life Insurance Payable to a Partnership: Private Letter Rulings 2009-47-006 (November 20, 2009), 2009-48-001 (November 27, 2009) and 2009-49-04 (December 4, 2009)
IRS Says the Options for Post-Tax Dollars in a Qualified Plan are Limited: Notice 2009-68, I.R.B. 2009-39 (September 4, 2009)
Rolling Over a Community Property IRA: Private Letter Ruling 2009-50-053 (December 11, 2009)

2010 Estate Tax Repeal? Watch Out for Flying Pigs!
Surrender of Bank-Owned Life Insurance is Deductible; “Basis” is Lower than “Investment in the Contract”: Private Letter Ruling 2009-45-032 (November 6, 2009)
Someone Other than the Donor Treated as the Owner for Income Tax Purposes – Another Piece in the Puzzle: Private Letter Ruling 2009-49-012 (December 4, 2009)
Brief Summaries