IRS Concession Regarding the Private Foundation/Self-Dealing Rules
Bob Murray and Katie French of our office have just resolved a multi-million dollar case with the Internal Revenue Service in which the Service conceded the proposed imposition of excise taxes under I.R.C. § 4941(a)(1) and (b)(1). The case in point involved the early termination of a Charitable Remainder Unitrust (“CRUT”). The IRS conceded the issue of self-dealing after the taxpayers demonstrated that they had followed the rationale of a [...]