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Home > Personal Income Tax Planning > An unallocated arbitration award, as well as the limits of Cohan
Podcast: Personal Income Tax Planning
Episode:

An unallocated arbitration award, as well as the limits of Cohan
Category: Business
Duration: 00:00:00
Publish Date: 2005-09-23 14:00:00
Description:

This Podcast deals with arbitration awards and IRA accounts.

What happens when a taxpayer is awarded an amount in arbitration regarding the management of an IRA account, but the award is paid to the taxpayer? Can these funds be put back into the IRA?

We consider three IRS private letter rulings on the subject to show both what has worked and what has not, at least in the IRS's view.

We also look at the case of a taxpayer who tries to invoke the Cohan case, only to have the Tax Court explain the limits of the use of that case. As well, the court points out that merely because the IRS settled a similar case in a certain manner doesn't entitle the taxpayer to the same settlement. The case is Stewart v. Commissioner, TC Memo 2005-212.

Be sure to download the related materials for this podcast from this link.



This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com

Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

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