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Curtis Elliott
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I am a tax lawyer and trusts and estates litigator in Charlotte, North Carolina
I am a tax lawyer and trusts and estates litigator in Charlotte, North Carolina

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Sixth Circuit Limits Scope of Substance Over Form Doctrine
The U.S. Court of Appeals for the Sixth Circuit recently dealt a significant taxpayer victory in Summa Holdings, Inc. v. Commissioner , No. 16-1712 (Decided February 16, 2017), and limited the government's ability to assert the substance over form doctrine ...

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STATE TAX RESIDENCY CASE WON BY SELLING BUSINESS OWNERS
The North Carolina Court of Appeals recently decided in Fowler v. North Carolina Department of Revenue , No. COA-14-1302 (August 8, 2015) that the owners of a construction company in Raleigh owed none of the $10.4 million capital gains tax from the sale of ...

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Crummey Trusts Continue to Be Approved By Tax Court
The U.S. Tax Court recently held in Mikel v. Commissioner , T.C. Memo 2015-16 that so called "Crummey" gifts of $12,000 each to 60 trust beneficiaries qualified for the annual gift tax exclusion as present interest gifts.  The IRS argued that although the t...

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McIlroy at the Wells Fargo Champioship
Case example of McIlroy's level of excellence at the Wells Fargo Championship:  On Sunday on hole number 16, Rory hit his drive 364 yards in the middle of the fairway.  He then flushed a wedge 140 yards to about 3 feet from the hole and tapped in his birdie...

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IRS Appeals Addresses Estate Tax Case Development (2014)
The IRS Office of Appeals has addressed estate tax case procedures in accordance with its new "judicial approach and culture (AJAC).  One new procedure is a reduction in the number of days remaining on the statute of limitations Appeals will hold the case. ...

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Estate and Gift Tax Litigationin the U. s. Tax Court

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