The Sale of a Business – Part 3: Due Diligence

One of the more common engagements for our firm is to assist with business sales and acquisitions. This article is the third in a series of articles which will walk through and generally discuss the steps typically associated with the sale of a business. In Part 1, we discussed the breakdown of the business, the…
Read More

Asset Protection Trust Protects Assets from Income Tax Liabilities

In the recent Tax Court opinion, Campbell v. Commissioner, T.C. Memo 2019-4, the Court held that assets in a self-settled offshore asset protection trust were not includable in assets collectible by the IRS to satisfy the taxpayer’s assessed income tax liabilities. The case involved John Campbell’s request for an Offer in Compromise, offering $12,603 to…
Read More

Law Firm Technology – An Open Discussion

At our firm, we use a host of technological tools. As the attorney responsible for research, acquiring, and implementing our tools, I am required to invest a tremendous amount of time in our tools. This article changes pace a bit and may be geared to a different audience, our peers, in hopes to engage in…
Read More

Legislation Proposed to Modernize Mississippi Trust and Estate Laws

The Mississippi House of Representatives is currently considering a pair of bills that could have a major impact on trust and estates in Mississippi. The bills, H.B. 1375 and H.B. 1425, are the product of a study committee formed by the Secretary of State and touch on a broad range of subjects, including non-probate transfers, transfer…
Read More

2019 Heckerling Takeaways – Gray Edmondson

Whenever I attend a large conference, I try to take some time afterwards to consider the most important takeaways. Having just returned from the 53rd Annual Heckerling Institute of Estate Planning which was held from January 14-19, 2019, I spent the last week reviewing the conference materials and my notes. From this, I have compiled…
Read More

Don’t Be SOL Because of the SOL

The federal government shutdown is stretching into week four, and there is no end in sight. The shutdown has affected all federal agencies and courts, including the United States Tax Court. One question raised by the shutdown is what effect does it have on Tax Court filing deadlines? The question is important because statutory filing…
Read More

Lock It in Now: Deduction for Alimony Set to Expire After 12/31/18

Lock It in Now: Deduction for Alimony Set to Expire After 12/31/18 As part of the Tax Cut & Jobs Act of 2017 (the “TCJA”), Congress included provisions to repeal the deduction of alimony under Internal Revenue Code (“IRC”) § which called for a corresponding inclusion of alimony in the income of the recipient where such…
Read More

Wendell Falls Again: Taxpayer Denied Second Bite at Easement

Original Tax Court Opinion I have previously written about the case of Wendell Falls Development, LLC v. Comm’r, T.C. Memo 2018-45. In that case, the Tax Court denied a charitable conservation easement deduction relating to a 125-acre parcel that was part of a total 1,280-acre development outside of Raleigh, North Carolina. I noted that the…
Read More