Beverly Hills, CA
Estate planning Lawyer at Beverly Hills, CA
Practice Areas: Estate Planning, Probate
OUTCOME: Full amount of mortgage was allowed as discount on audit of estate tax return.
Real property was fractionalized between revocable and irrevocable trusts. Minority and marketability discount was taken in valuation for estate tax purposes. Recourse mortgages were deducted at full v ... alue and not discounted for minority and marketability, ie they were not netted against property values before discounting.
OUTCOME: No income when ISO stock put into trust.
An employee was issued Incentive Stock Option Stock by his employer .He did not recognize income when the option to purchase was issued to him and he did not recognize income when he exercised the opti ... on and acquired the stock. There was substantial deferred gain, that being the difference between what he paid for the stock and what it was worth. The employee and his wife had created a revocable trust. The employee transferred the stock to the trust. When ISO stock is disposed of within a certain time period, the deferred gain becomes immediately taxable. The employer took the position that the transfer to the revocable trust was a disposition and it issued a form 1099 to the employee. The employee then asked me to apply on his behalf to the Internal Revenue Service for a private letter ruling stating that the transfer was not a disposition and that taxpayer did not recognize income. I obtained a 100% favorable ruling. It is described in an article I wrote entitled'When the Transfer of Incentive Stock Option Stock to a Trust Will Be Treated as a Taxable Disposition' ,which was published in Estate Planning, Trust & Probate News Fall 1991 Volume 11 No. 3 at page 14. A complete copy of the ruling is attached to the article.
OUTCOME: Non-profit status granted by IRS
I volunteered to incorporate a program for unemployed youth in the San Francisco area. I volunteered to assist the corporation in applying to the IRS for non-profit status. All IRS, Franchise Tax Board ... and Attorney General forms were filed. The IRS granted the corporation non-profit status as requested.
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