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Estate, Gift & Trust Tax

Estate Tax 

 


New York Proposed State Estate Tax Changes

February 14, 2014

In what may be a harbinger of things to come among the states that continue to have an estate tax, New York Governor Cuomo proposes (the proposal) raising over time the state’s estate tax exemption to $5.25 million by 2019 together with indexing the exemption to inflation and lowering the top estate tax rate to 10 percent. New York’s current exemption is $1 million with a top rate of 16 percent. Beginning in 2019, New York’s estate tax exemption would match the Federal exemption, which is also indexed to inflation. In addition, the state’s generation-skipping transfer tax will be repealed.

On the negative side, under the proposal New York’s gift tax will come back (albeit in an indirect manner), and New York residents will be taxed on income from certain types of trusts which income is not currently taxed by the state.

While there is a gift tax at the federal level, New York’s gift tax was repealed in 1999. Accordingly, New York residents currently can make gifts (even just before death) free of state gift tax. Once a gift is completed, the assets will not be subject to New York estate tax. The proposal would change this by requiring all gifts made by New York residents on or after April 1, 2014, to be added back to the taxable estate on death. This change means that the assets gifted become subject to the state’s estate tax. This is effectively a tax on gifts. The tax rate on a gift once the rate adjustments end will range from 6.5% to 12% of the New York gross estate, now including taxable gifts, if the estate exceeds the then state’s exclusion amount. If enacted, consideration needs to be given to: (a) the deductibility for Federal estate tax purposes under IRC §2058 of this tax on the gift (deductibility under IRC §2058 appears to require that the tax be on assets includible in the gross estate for Federal estate tax purposes, which is not the case here), (b) apportionment clauses in wills and trusts that direct who will pay taxes at death (a new tax to deal with) and the effect of the payment on other gifts passing at death under the will or trust (such as a marital formula clause), (c) use of a net gift where the donee assumes liability for any gift/estate tax, and (d) the need for a written agreement between the donor and donees to address these issues.

The proposal also impacts certain types of trusts structured from an income tax perspective to “reside” outside of New York so as to avoid its income tax on the accumulated income from the assets in such a trust. The proposal requires New York resident creators or beneficiaries of such trusts to include accumulated income of those trusts for purposes of state income tax. If adopted, this proposal would become effective beginning June 1, 2014.

With the very short time-frames between enactment and effective date, planning for these proposed changes to New York’s tax treatment of gifts and trust taxation will be difficult. To the extent meaningful gifts are contemplated this year or contemplated in future years as part of an ongoing estate plan, it would be advisable to consider completing them before April 1, 2014 and reconsider or revise such an estate plan.

If the above changes are made by a state as large and influential as New York and with the large number of states that do not have an estate tax (only 15 states appear to have a state estate tax), it is foreseeable that states that have state estate taxes will follow with changes of their own.

Disclaimer: This article is designed to provide information in regard to the subject matter and has been prepared with the understanding that neither the Illinois CPA Society nor the author of this article is providing accounting, tax or legal advice or is performing any legal, accounting or other professional service. If accounting, tax or legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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Unified Credit Portability Election

February 1, 2014

 Claireen L. Herting

Specialized Tax Consulting. Ltd

clhert@sbcglobal.net

 

Key Highlight: IRS issues Revenue Ruling providing relief for making a late Unified Credit Portability Election for Estates of Decedents who died before 2014.


Portability of the unified credit of the first spouse to die to the surviving spouse was first enacted effective  January 1, 2011 and made permanent by the American Taxpayer Relief Act of 2012. When a decedent  dying on or after January  I , 2011 is survived by a spouse, the amount of the unified credit available  to that decedent's estate for estate tax purposes that is not used by that estate for estate tax purposes is portable and can be used for gift or estate tax purposes by the surviving spouse.

 

Section 2010 (c) (5) (A) specifically  states that the deceased spouse's unused unified credit amount cannot  be used unless the executor  of the deceased  spouse  timely files an estate tax return which  indicates the amount and makes an election  that such amount may be taken into account.  Consequent ly, even if no estate tax return is due because the amount of the decedent's gross estate was under the amount required  to file a return, a return is required to be filed to elect portability.  If the executor  failed to file a return, he could seek relief under the Treasury  Regulation  Section 301.9100-3.

 

Revenue Procedure  2014-18  provides a simplified  method for executors to obtain an extension of time to tile a return and elect portability if they did not tile a return because the only reason to do so was to elect portability. The simplified  method is to simply file the otherwise  late estate tax return, on or before December  31, 2014, and at the top of the first page of the return state: "FILED  PURSUANT TO REV. PROC.

2014-18 TO ELECT PORTABILITY UNDER SECTION 2010 (c) (5) (A)."  The return must then be prepared  in accordance with Ref?;. Section 20.2010-2T (a) (7). However, this relief is only applicable  to predeceased spouses who died in 2011, 2012 or 2013 and the late estate tax return is filed on or before December  31, 2014. Under Section 2203 and Reg. Section 20.2010-2T (a) (6) (ii), if no executor or administrator of the first to die spouse's estate is appointed.say by a probate court, an ''executor" is any person in actual or constructive possession of any property of the decedent.

 

If the surviving spouse has died and an estate tax return was filed without the benefit of portability, a protective  election  may be due as early as October  L 2014.

 

There is no user fee charged  for filing under this revenue  procedure so it is more favorable and there is much less uncertainty than asking for relief under Section

301.9100-3.

Disclaimer: This article is designed to provide information in regard to the subject matter and has been prepared with the understanding that neither the Illinois CPA Society nor the author of this article is providing accounting, tax or legal advice or is performing any legal, accounting or other professional service. If accounting, tax or legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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2014 Transfer Tax Inflation Adjustments
December 5, 2013
In Rev. Proc. 2013-35 the IRS has announced several of the transfer tax related inflation adjusted amounts for 2014.

Inflation-adjusted figures for the year that were released include:

The annual exclusion from the gift tax will remain at $14,000 per donee (§2503).
The basic exclusion amount is increased from $5,250,000 to $5,340,000 for determining the amount of the unified credit against estate tax under §2010.
The annual exclusion amount for gifts to a non-citizen spouse (§§2503 and 2523(i)(2)) will increase to $145,000.
The cap on the reduction of value for purposes of the special use valuation rules (§2032A) will increase to $1,090,000.
The amount used in computing the "two-percent portion" (for purposes of calculating interest under §6601(j)) for purposes of the installment payment of estate taxes (§6166) will be $1,450,000.

In determining whether the “Expatriation to Avoid Tax” applies, an individual with “average annual net income tax liability” of more than $157,000 for the five taxable years ending before the date of the loss of United States citizenship under §877(a)(2)(A) is a covered expatriate for purposes of §877A(g)(1). (information on this and the following paragraph to be provided in form 8854, Initial and Annual Expatriation Statement)
The amount that would be includible in the gross income of a covered expatriate by reason of §877A(a)(1) is reduced (but not below zero) by $680,000, for purposes of determining the “Tax Responsibilities in Expatriation.”

The amount used by the donee to determine if the receipt of gifts from certain foreign persons must be reported (§6039F) is if the aggregate value of gifts received in the year is $15,358 or more, see the multipurpose Form 3520 and its instructions.

Early and Often: remind clients of the power of making annual gifts of $14,000 per person each year to utilize the annual federal gift tax exclusion. Such gifts do not use the above mentioned basic exclusion amount. The gift tax annual exclusion amount does not carry over or accumulate to other years. A client may not survive the year, so making gifts early in the year is advised. In this planning be careful to discuss with the client gifts, if any, which reduce the $14,000 that the client may not be aware of having already been or will be made, such as gifts made to existing trusts (i.e., gifts to trusts with Crummey powers given to children, grandchildren, etc. such as irrevocable gift or life insurance trusts), etc. If possible keep it simple, use separate accounts if a couple have them and, also, avoid gift splitting.

Disclaimer: This article is designed to provide information in regard to the subject matter and has been prepared with the understanding that neither the Illinois CPA Society nor the author of this article is providing accounting, tax or legal advice or is performing any legal, accounting or other professional service. If accounting, tax or legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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Executor and Trust Held Personally Liable for Illinois Estate Tax

March 25, 2013

Summary: The executor and trustee is personally liable for failure to pay additional Illinois estate tax arising after a federal estate tax audit, even though the Illinois Attorney General issued a Certificate of Discharge and Determination of Tax upon the filing of the original Illinois estate tax return.

Discussion: The Illinois estate tax in 2002 was the amount equal to the federal state death tax credit. Under Illinois law, the procedure for filing Illinois estate tax returns and the responsibility for paying the tax due is tied to the federal estate tax law. See 35 ILCS 405/6 (herein “section 6"). The personal liability of a fiduciary is also tied to the federal estate tax law. See 35 ILCS 405/10( c) (herein “section 10").

Julius Kole (Kole) was appointed executor and successor trustee of the decedent’s (Anthony Crespo’s) estate and revocable trust respectively. Kole made payment of Illinois estate tax when timely filing the request for an extension of time to file. The request was granted. Kole then timely filed the Illinois estate tax return with a copy of the timely filed federal estate tax return attached. The Illinois estate tax return as originally filed reported an overpayment of tax due. The Illinois Attorney General then issued a Certificate of Discharge and Determination of Tax.

The IRS audited the federal estate tax return causing an increase in the federal state death tax credit of approximately $162,000. After the audit, Kole did not file an amended/supplemental Illinois estate tax return to report and pay the additional Illinois estate tax, interest and penalties due as a result of the increase in the credit. The Illinois Attorney General then filed suit seeking additional Illinois estate tax, interest and penalties and the personal liability of Kole for same.

Kole moved to dismiss the complaint, alleging the Certificate of Discharge and Determination of Tax that was issued released him from personal liability for the additional Illinois estate tax, interest and penalties. Kole also argued that other sections of 35 ILCS 405 also preclude personal liability. The Illinois Attorney General motioned for summary judgment for the additional estate tax and against Kole personally. The trial court found for Kole, stating that the statute did not impose personal liability for the additional Illinois estate tax owed, and dismissed the Illinois Attorney General’s motion.

Decision: Trial court’s opinion reversed. Kole as executor and trustee is personally liable for the underpayment of the additional Illinois estate tax, interest and penalties. The court first found that the issuance of the Certificate of Discharge by the Illinois Attorney General did not discharge Kole from personal liability for the additional tax. The court noted the certificate itself applies “only to the liability reflected therein and the figures and information upon which that liability was calculated.” The certificate does not discharge the personal liability for all Illinois estate taxes due if the information submitted on the Illinois estate tax return is inaccurate. The court then found that the other sections of 35 ILCS 405 did not limit the Illinois Attorney General to the issuance of only one certificate. The court then noted: “Given that section 6(c) clarifies the duty and instructs that the federal filer must file all returns and pay all estate taxes, section 10(c), we believe, unambiguously, and without the need to again state that the foregoing terms include supplemental returns and additional taxes, imposes personal liability on the federal filer for the failure to file any return and/or pay any estate tax.”

Disclaimer: This article is designed to provide information in regard to the subject matter and has been prepared with the understanding that neither the Illinois CPA Society nor the author of this article is providing accounting, tax or legal advice or is performing any legal, accounting or other professional service. If accounting, tax or legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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American Taxpayer Relief Act of 2012 as it relates to Estate and Gift Tax

February 19, 2013

Beth Cwik 
Huck Bouma PC 
bcwik@huckbouma.com

While the uncertainty of the 2013 Estate, Gift and GST Tax exemption and rates made 2012 year-end planning a challenge, for the first time in 12 years, Congress was successful at approving permanent estate, gift and generation-skipping transfer (GST) tax provisions. These provisions reside in the “American Taxpayer Relief Act of 2012.”

While the estate tax exemption remains at $5 million (indexed for inflation since 2011) the 2012 exemption amount is $5.12 million and increases to $5.25 million for 2013. The only change to the tax rate was an increase from 35% to 40% effective January 1, 2013.

Congress has also kept the gift tax exemption and GST exemption the same which were $5.12 million in 2012 and $5.25 million in 2013. The gift tax rate has increased from 35% in 2012 to 40% in 2013 while the annual exclusion has increased from $13,000 in 2012 to $14,000 in 2013. State estate taxes continue to be deductible for federal estate tax calculations. The Act also makes portability permanent.

Other notable permanent items are the technical provisions enacted in 2001 regarding allocation of GST exemption and the GST inclusion ratio.

Section 208 of the American Taxpayer Relief Act of 2012 also extends to December 31, 2013 the tax-free distribution from an individual’s IRA for charitable purposes as long as the individual is 70 1/2 on the day of the transfer. The transfer is limited to $100,000 per individual. The taxpayer may also elect to treat a distribution made between December 1 and December 31, 2012, as a charitable distribution as long as the contribution to the qualified charity is made before February 1, 2013. The distribution must qualify under the general charitable rules of Section 170.

Disclaimer: This article is designed to provide information in regard to the subject matter and has been prepared with the understanding that neither the Illinois CPA Society nor the author of this article is providing accounting, tax or legal advice or is performing any legal, accounting or other professional service. If accounting, tax or legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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Estate of Lockett v. Commissioner

 

September 21, 2012
 

David Lynam 
Lynam & Associates 

Tax Ct: FLP Declared Invalid- All FLP assets found to be included in decedent’s estate 

The United States Tax Court, in Estate of Lockett v. Commissioner, (April 25, 2012) recently found that all of the assets of an initially valid Family Limited Partnership (“FLP”) were includable in the gross estate of the decedent, after finding that the FLP participants had failed to maintain the FLP’s existence.

The Lockett family executed an FLP operating agreement for an Arizona limited liability limited partnership, which named Mrs. Lockett’s two sons as general partners, and herself, Trust A (a trust in which she had a right to withdraw principal and a general power of appointment), and her two sons as limited partners. Thereafter, only Mrs. Lockett and Trust A actually contributed assets to the FLP. The record indicates Mrs. Lockett’s frail health and an effort to engage in tax planning, but mainly disinterested and disjointed actions on the part of her heirs and advisors. Her sons’ contributions as general and limited partners were never determined, and after its creation they had no actual involvement with the FLP or its activities, nor did they transfer any property to the FLP. Prior to her death, Mrs. Lockett terminated Trust A (which had been made a limited partner of the FLP) and appointed the assets to herself. The partnership agreement provides that the partnership would dissolve upon all of the interests owned by a single partner.

Following her death, the IRS issued a Notice of Deficiency on grounds that the FLP was never a business operated to derive a profit, or alternately, that, as Mrs. Lockett’s two sons had failed to become partners, the FLP dissolved upon the voluntary termination of Trust A, then the only other partner in the FLP.

The Court found that the making of investments, the sale of real estate, and the making of loans to family members was sufficient to constitute operating a business for profit. As to the issue of the failure of the sons to become partners, the estate argued that under Arizona law, general partners are not required to make capital contributions to acquire an interest in a partnership. The tax court dismissed this argument, noting that the FLP agreement explicitly required partners to contribute capital in exchange for their interests. Conceding that Mrs. Lockett’s sons had not contributed cash or property to the FLP, the estate then argued that her sons had instead acquired a partnership interest in the FLP in exchange for performance of services, or, alternatively, by gift from Mrs. Lockett. Neither son had any direct involvement in the FLP’s investment activities, and so the estate could only argue that the sons’ requisite “service” to the FLP was their agreement to serve as general partners in the partnership agreement. The Court instead found only evidence that the FLP was managed by its attorneys, accountants and financial advisor, and not by the sons. The court was also unable to discern any intent by Mrs. Lockett to confer partnership interests to her sons by gift.
Amendments to the FLP appeared to support Mrs. Lockett owning 100% of the FLP, and no interest owned by the sons. Neither the U.S. 1065 for the FLP, the Lockett sons’ U.S. 1040’s, nor Mrs. Lockett’s own individual returns supported any ownership by the sons, whether by gift or otherwise, until after her death.

The Court also examined whether several transfers made by the FLP to family members were loans, as claimed, or gifts, citing the general rule that transfers to family members are presumptively gifts absent a showing that the party making the transfer had expectations of repayment and intended to enforce the debt. The Court was persuaded where it found loan treatment of the transfers by the FLP’s accountant, who had prepared notes (both signed and unsigned) and amortization schedules, booked the transfers as loans, and reported them as such, coupled with demands for repayment.

As the FLP dissolved when no association of two or more persons existed, the decedent held 100% of legal and beneficial interest in the assets of the FLP at death. This case is perhaps one of many case studies in how not to set up and operate a FLP.

 

Disclaimer: This article is designed to provide information in regard to the subject matter and has been prepared with the understanding that neither the Illinois CPA Society nor the author of this article is providing accounting, tax or legal advice or is performing any legal, accounting or other professional service. If accounting, tax or legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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 Estate Tax Deadline for Portability Extended 

 

March 12, 2012

Michael Deering 
Mowery &Schoenfeld, LLC 
mdeering@msllc.com

Key Highlight: The IRS has extended the deadline to make the portability election by allowing an otherwise late filing of an estate tax return for decedents survived by a spouse who died during the first six months of 2011.


On Friday, February 17th the Internal Revenue Service published Notice 2012-21. The notice gives executors the ability to extend the original filing of an estate tax return in order to preserve the portability of the surviving spouse’s $5 million exemption. This extension applies when the executor of a qualifying estate did not timely file Form 4768 (Application for Extension of Time To File a Return and/or Pay U.S. Estate (and Generation-Skipping Transfer) Taxes). The following is required to qualify for the extension:

• Decedent must have died within the first 6 months of 2011,
• Decedent’s gross estate cannot exceed $5million,
• Form 4768 must be filed with 15 months of the decedent’s death.


Form 706 of a qualifying estate will be due 15 months after the decedent’s date of death. The first of these extensions and the Form 706 will be due by April 2, 2012.

Additional information can be found on the IRS website.

Disclaimer: This article is designed to provide information in regard to the subject matter and has been prepared with the understanding that neither the Illinois CPA Society nor the author of this article is providing accounting, tax or legal advice or is performing any legal, accounting or other professional service. If accounting, tax or legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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Latest Attempt to Limit Crummey Withdrawal Rights Rejected by Tax Court

 

 

January 18, 2012

 

Jeffrey T. Conrad & Damien R. Martin 
Wolf & Company, LLP 
jeff.conrad@wolfco-fs.com and damien.martin@wolfco-fs.com

Key Highlight: Tax Court rejects IRS argument that contributions to an irrevocable life insurance trust failed to qualify as a present interest gift, subject to the gift tax annual exclusion, because the donor paid life insurance premiums directly to a life insurance company.

The Tax Court was presented with and turned away the Internal Revenue Service’s (the “Service”) latest attempt to limit the scope of so-called “Crummey” withdrawal rights in Estate of Clyde W. Turner, Sr., et. al., TC Memo 2011-209.

Case Summary --

The facts relative to the gift tax annual exclusion (withdrawal rights) issue were quite simple. The decedent established an irrevocable life insurance trust (“ILIT”) in 1992. From 2000 to 2003, the decedent paid the insurance premiums on behalf of the ILIT directly to the life insurance company from a joint checking account; no funds were transferred to the trustees of the ILIT to pay the premiums.

The Service argued that the indirect contributions failed to qualify as present interest gifts, subject to the gift tax annual exclusion, for two reasons: (1) the withdrawal rights were illusory because the donor did not deposit the money with the trustee and (2) the beneficiaries did not receive notice of the indirect contributions.

The Tax Court rejected both arguments. Citing Crummey v. Commissioner, 397 F. 2d 82 (9th Cir, 1968) and Estate of Cristofani v. Commissioner, 97 TC 74 (1991), the Tax Court explained that the test for distinguishing a present interest gift under Internal Revenue Code (“Code”) Section 2503(b) from a future interest is whether the beneficiary had a legal right to demand property, not whether the beneficiary was likely to receive present use and enjoyment from property. The Court then went further, following the 9th Circuit Court of Appeals conclusion in Crummey, and held that the ability to demand property from a trust, which cannot be legally resisted by the trustee, constitutes a present interest under Code Section 2503(b), regardless of whether the beneficiary has knowledge of the withdrawal right.

In this particular case, the beneficiaries were granted withdrawal rights for each direct and indirect transfer to the trust. Emphasis added. Because the trust agreement provided for withdrawal rights over both direct and indirect transfers, the Tax Court held that the fact that the decedent did not transfer funds to the trusts was irrelevant.

With respect to the notice argument, the Court also found that knowledge, or lack thereof, of withdrawal rights did not affect the legal rights of the beneficiaries to exercise withdrawal rights granted under the trust agreement. Based on those findings, the Tax Court held that the life insurance premium payments were present interest gifts to the ILIT that qualified for the gift tax annual exclusion.

Planning Considerations –

This is the latest example of the Service’s focus on narrowing the application of withdrawal rights on trust contributions, as a means of qualifying for the gift tax annual exclusion(s). There have been a series of cases attempting to limit withdrawal rights through various legal theories, and at this point, there is no indication that the Service will back away from this aggressive posture.

That being the case, there are two planning points to take from this case. The primary point is related to drafting. An irrevocable trust that includes withdrawal rights should be drafted as broadly as possible to apply withdrawal rights to both direct and indirect transfers. This broad application should prevent the form over substance position that the Service tried to advance in this case.

The second planning point is related to withdrawal right notices. All possible steps should be taken to provide beneficiaries notice of withdrawal rights when contributions are received, and that notice should be documented for cases such as this one. With proper documentation, the Service’s second argument in this case could have been easily avoided.

 

Disclaimer: This article is designed to provide information in regard to the subject matter and has been prepared with the understanding that neither the Illinois CPA Society nor the author of this article is providing accounting, tax or legal advice or is performing any legal, accounting or other professional service. If accounting, tax or legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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Filing Protective Claims under Section 2053, Rev. Proc 2011-48

January 17, 2012

Gary S. Hart

Gary Hart & Associates, Ltd.

Key Highlight:    The IRS recently issued Rev. Proc. 2011-48 explaining how estates are to file protective claims under Section 2053

In 2009, the IRS published final regulations regarding the deductibility of claims made against an estate (see Estate, Gift & Trust Committee Tax Alerts & Articles dated February 5, 2010 and June 25, 2007)  ). As a follow-up to the regulations, the IRS on October 14, 2011, issued Revenue Procedure 2011-48, explaining the procedure for filing protective claims under the Section 2053 regulations.

In general, Section 2053 provides for the deductibility of funeral and administrative expenses, as well as for claims against the estate.  Some expenses, such as funeral expenses and mortgages payable, will be known at the time an estate tax return is filed.  However, other expenses may not be known, particularly those involving estate litigation.  The regulations issued in 2009 address the requirements for making protective claims for those amounts which are not known at the time an estate tax return is filed.

The 2011 Revenue Procedure provides that for estates of decedents dying on or after January 1, 2012, a new Schedule PC will be available for the first time to attach to the 2012 Form 706.  A section 2053 protective claim for refund may be filed by attaching one or more completed Schedule PC's to the estate's Form 706.  A separate Form PC should be included for each outstanding claim or expense that forms the basis of a deduction under section 2053.

For decedents dying after October 19, 2009 (the effective date of the Rev. Proc., as well as the final regulations under Section 2053) and before January 1, 2012, a section 2053 protective claim may be filed by filing Form 843 with the notation "Protective Claim for Refund under Section 2053" entered across the top of page 1 of the form.  Form 843 may also be used for decedents dying on or after January 1, 2012 where the 2012 Form 706 is filed without a completed Schedule PC when it is subsequently determined that a protective claim is warranted.

Additional information regarding the timing and who may file a protective claim may be found in Rev. Proc. 2011-48.

Disclaimer: This article is designed to provide information in regard to the subject matter and has been prepared with the understanding that neither the Illinois CPA Society nor the author of this article is providing accounting, tax or legal advice or is performing any legal, accounting or other professional service. If accounting, tax or legal advice or other expert assistance is required, the services of a competent professional person should be sought.

 

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