On the one hand, they may choose to defer incurring
any investigative or remedial costs until either a claim is filed against them that creates a right to contribution under Section 113(f)(1) or they reach an administrative settlement with the government that triggers the right to contribution under Section 113(f)(3)(B).
Lincoln Life's offering is through a rider that gives policyholders the right to surrender their universal life contracts without incurring
surrender charges if Congress extends repeal of federal estate taxes through at least Jan.
Establishing a prudent policy of periodic repairs and incurring
expenses under that policy do not, in our view, transmogrify periodic repairs into a capital asset with a useful life beyond the year incurred.
Finally, the IRS initially failed to take into account the unique factual situation presented in TAM 9541005, where the party incurring
the costs was the same party who contaminated it, and that party had owned the land continuously except for the three years when the county had title.
In Wolfsen, incurring
the expenditures was essential to the production of future income from the farming activity.
Accordingly, during the following months, taxpayers incurring
package design costs were prohibited from capitalizing and amortizing those costs under Rev.
Generally, a taxpayer can give $11,000 ($22,000 for married couples) per year to any individual without incurring
some capitalized expenditures does not automatically indicate a rehabilitation plan exists (as in Situation 2).
The IRS has publicly ruled it possible, under certain circumstances, for a partner to exchange a general partner interest for a limited partner interest (or vice versa) without incurring
tax liability from the transaction.
It was this income benefit that was the primary purpose for incurring
The attorney suggested that an S election would solve the problem, by allowing Gene to withdraw the corporate net income as tax-free distributions without incurring
double taxation or payroll tax on salaries.
The increase in the unified credit (now referred to as the applicable credit amount), enacted as part of the Taxpayer Relief Act of 1997 (the TRA '97), enables taxpayers who have made gifts in excess of the "old" unified credit to make additional gifts without incurring