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Tax Returns, Examinations & IRS Procedure

This library contains hundreds of high-quality technical tax memoranda on a wide variety of topics. The memoranda are organized by topics and are fully word-searchable. This library is a rich resource of already-solved tax problems. Use it as a starting point for your own research.

The Tax Resource Group: Professional Tax Research Material, Resources, and Consulting

The Tax Resource Group Memo Library

Category: Estate and Gift

Contribution of Loss Property to Partnership; Interaction of Section 1015 and the Partnership Basis Rules; IRC: 1015, 704(c), 722.

Controlled Group of Corporations; Effect of Stock Gifts to Adult Offspring, Attribution Rules; IRC: 1563.

Deceased S Corporation Shareholder; NOL and Basis Considerations; IRC: 469(g); 1366(d), 1015(a).

Estate; Valuation of Lawsuit Settlement; IRC: 2031, 7520.

Exclusions; Exclusion for Family-Owned Business; IRC 2032A.

Generation Skipping Tax; Direct Transfers vs. Transfers in Trust; IRC: 2611, 2612.

Gifts; Gifts Within Three Years of Death; IRC: 2035(a).

Gift of Limited Partnership Interest; Various Issues; IRC: 1001, 1041.

Gift or Compensation?; Gift of Stock in Commercial Context; IRC: 61, 102, 311(b) and 336.

Gift Tax; Consequences of Loan Guarantee; IRC: 2501.

Gift Tax and Dependents; Gift to Non-Minor Dependents; IRC 2501.

Gratuitous Forgiveness of Mortgage Loan; Inclusion of Accrued Interest in Taxable Gift/Inclusion of Accrued Interest in Income; IRC: 61, 2501.

Installment Sales; Self-Canceling Installment Notes; IRC: 102, 453B, 61(a)(12).

Interest Paid to Foreign Lender/Gifts by Nonresidents; Various Issues; IRC: 102, 267(a)(3), 1442, 1441, 2501(a)(2).

Part-Gift, Part-Sale of Home; Various Issues; IRC: 1034, 121, 2501.