Federal Tax Update

Attorney-CPA, The, Oct 2004 by De Jong, David S

In Letter Rulings 200417033. 200422053. 200422058 and 200423038, IRS declined to waive the 60-day rollover rule for an unemployed taxpayer, who needed to avoid foreclosure on his home pending a loan from his mother, for an unemployed taxpayer who needed to pay tuition expenses, for a taxpayer who subsequently learned of the adverse tax consequences and for a taxpayer who expected but failed to have funds for a timely redeposit.

In Letter Ruling 200422050, IRS interpreted Revenue Procedure 2001-38 as not permitting revocation of a QTIP election in part; only a revocation in full can be sought.

By

David S. De Jong

Stein Sperling, et al, Rockville, MD