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Final Regs on Income Ordering Rules for Payments to Charitable Beneficiaries

For a trust to qualify for the charitable deduction, a charitable contribution must be made from gross income. [ See IRC § 642(c) .] IRC Section 642 requires tracing since the source of the charitable contribution must be gross income rather than principal. The provisions of the governing instrument...

Tax Court Finds IRS Compliance Officer Liable for Civil Fraud Penalty

Readers interested in the risks of being audited with respect to income tax noncompliance arising from foreign assets (particularly financial accounts) often ask what it takes for the IRS to prove fraud. I am aware of no standard litmus test of civil tax fraud that will identify, particularly for laymen...