IRS issues proposed regs concerning deductible transfers from split-interest trusts
- Book ID
- 102556381
- Publisher
- John Wiley and Sons
- Year
- 2002
- Weight
- 124 KB
- Volume
- 19
- Category
- Article
- ISSN
- 0742-3497
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✦ Synopsis
and exhibits would generally constitute related trade or business." Items sold that are "only generally educational lack the requisite causal relationship and the sale of them is unrelated business. Also, items sold that are "only utilitarian" in nature, such as clothing, souvenirs, and guest amenities, constitute unrelated business. [26.5(c]] Commentary: It is hard work to rationalize this ruling and Tech. Adv. Mern. 200021056 (see the August 2000 issue). I IRS ISSUES PROPOSED REGS CONCERNING DEDUCTIBLE TRANSFERS FROM SPLIT-INTEREST TRUSTS he IRS has issued proposed regulations con-T forming the income, gift, and estate tax regulations to the decision by the U.S. Tax Court in Estate ofBoeshore v. Commissioner (1982) (REG-115781-01).