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At one time, advice for saving for clooege often suggested that grandparents who were interested in assisting with their grandchildren's college costs open a 529 plan with themselves (or himseolf or herself, if widowed) as the account owner the grandchil as the beneficiary. Doing so avoided reported the 529 anywhere on the FAFSA, because it was not an account owned by the grandchild/student or the student's parents.

As I understand the FAFSA calculations of EFC (Expected Family Contribution) 20% of student's assets are deemed available and 5.65% (more or less) of parents' assets are deemed available for EFC. In terms of minimizing EFC parent assets are better than children's asset, but not as good as grandparents' assets. And available income (as opposed to assets) are expected to be contributed at even higher rates.

"You should be sure to understand the gift-tax consequences of your contributions to the 529 plan. Whether you contribute to accounts owned by you, or to accounts owned by the parents or someone else, your contributions are a gift from you to the account beneficiary (and a generation-skipping transfer if the beneficiary is your grandchild). For large contributions (over $14,000) you may elect on a gift-tax form to treat up to $65,000 of the contribution as made over a five-year period. This election allows you to frontload more contributions into a 529 plan without exceeding the $14,000 annual gift exclusion.

Caution: The IRS has not yet indicated whether a contribution you make to a 529 account owned by someone else will be treated as two gifts, the first from you to the account owner, and the second from the account owner to the beneficiary. Most tax practitioners believe there is only a single gift—from you to the account beneficiary—but the answer remains a bit uncertain."

http://www.savingforcollege.com/grandparents/answer.php?gran...

Has the question raised in the cautionary note been addressed?

I am no expert, but its seems to be an unusual construct to say the the same $14,000 is a gift to both the parents and to the grandchild.

"Simply owning a 529 account for your grandchild will not affect your grandchild’s eligibility for need-based financial aid, but actually using the account could have a negative impact in the subsequent year.

The value of assets owned by a grandparent (or other non-parent) is not reportable on the FAFSA financial aid application. This rule extends to 529 plans owned by grandparents.

However, if a grandparent provides any type of financial support to the student, that support is reportable on the following year’s FAFSA as student income. The financial aid formula counts student income just as it counts student assets (although the assessment percentages and allowances are different). Most financial aid offices interpret the rules as requiring distributions from grandparent-owned 529s to be included as student income, even when the distributions are not reportable for federal income taxes (i.e. they are tax-free)."

http://www.savingforcollege.com/grandparents/answer.php?gran...

A recent post (on this board, IIRC) caused me to double check this issue.

Question 44 on the FAFSA asks:

44. Student’s 2012 Untaxed Income (Enter the combined amounts for you and your spouse.)
. . .
j. Money received, or paid on your behalf (e.g., bills), not reported elsewhere on this form.

See http://www.fafsa.ed.gov/fotw1314/pdf/PdfFafsa13-14.pdf

AS a result money paid from a 529 plan is considered as student income the following year, and leads to a much larger expected contribution (even though there is no guarantee that future payments will be made [or even that there is still money available to be used for payments]).

With all of that background, and thanks to those who have read this far, if a grandparent owns a 529 plan for a grandchild, can the grandparent tranfer ownership of the account to the grandchild's parents without triggering a second gift tax?

If an immediate transfer the parents (as owner) and to the grandchild (as beneficiary) would trigger only one gift tax, then a subsequent transfer of account ownership would not appear to constitute a taxable gift, but I know enought o know that logic and taxes are only sometimes related.

Any thoughts from the resident tax pros, or any other readers?

Regards, JAFO (and thanks in advance)
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If an immediate transfer the parents (as owner) and to the grandchild (as beneficiary) would trigger only one gift tax, then a subsequent transfer of account ownership would not appear to constitute a taxable gift, but I know enought o know that logic and taxes are only sometimes related.

Any thoughts from the resident tax pros, or any other readers?


I would expect that every transfer of "ownership" would constitute a taxable gift. Transfer of assets to a beneficiary do not constitute a taxable gift because the tax code (Section 529) excludes the transfered amount from gift tax provided certain conditions are met. The "double gift" question rests on whether a contribution to a 529 plan owned by someone other than the donor constitutes a two-step transfer (to the owner and then to the plan) or is a direct transfer to the plan. I think it would be a stretch for the IRS to insist on the two-step interpretation.

On the other hand, transfer of plan ownership involves transfer of significant rights - namely, the right to determine how, when, and to whom to distribute the assets. This would certainly be a taxable transfer.

Ira
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irasmilo:


<<<If an immediate transfer the parents (as owner) and to the grandchild (as beneficiary) would trigger only one gift tax, then a subsequent transfer of account ownership would not appear to constitute a taxable gift, but I know enought o know that logic and taxes are only sometimes related.

Any thoughts from the resident tax pros, or any other readers?>>>

"I would expect that every transfer of "ownership" would constitute a taxable gift."

OK. That is sort of what I expected. I was hoping, however, than given that the grandparent has to file paperwork to accelerate annual exclusion amount meant that taxes had already been paid on the gift, and that the transfer of the ownership was more akin to appointment of a replacement trustee rather than a second gift.

"Transfer of assets to a beneficiary do not constitute a taxable gift because the tax code (Section 529) excludes the transfered amount from gift tax provided certain conditions are met."

Then why is there a provision allowing for a larger contribution in a single year (5x the annual exclusion amount) provided that the grandparent files appropriate paperwork allowing accelerated gifting of annual exclusion amount?

If transfer of assets to a beneficiary do not constitute a gift, why can a grandparent not contribute $100,000 to a 529 plan for a grandchild and not owe any gift tax?

"The "double gift" question rests on whether a contribution to a 529 plan owned by someone other than the donor constitutes a two-step transfer (to the owner and then to the plan) or is a direct transfer to the plan. I think it would be a stretch for the IRS to insist on the two-step interpretation."

This is what I also expected, but then why does a time separation generate a second tax when a simultaneous transaction would not? Is that not elevating form over substance?

"On the other hand, transfer of plan ownership involves transfer of significant rights - namely, the right to determine how, when, and to whom to distribute the assets. This would certainly be a taxable transfer."

Ok. Then if the goal is transfer from the grandparent to the parents before it is used, to avoid reporting it as grandchild's income (and to avoid using any lifetime credit), then I guess the usual rules of gifting apply --- transfer of the annual exclusion amount split over two years (given that is is now September) and to each of the parents of the grandchild . . . 14k in 2011 to one parent (to minimize amount reported on FAFSA filed in January or February 2014) and then 28k to both parents in 2014 after the FAFSA is filed would transfer 42k in within the next 4-5 months. Possible slightly more gifted in 2013 to the second parent if the total amount to be gifted in greater than 42k but less than 56k, or alternatively, simply transfer the amount in excess of 42k in 2015 after FAFSA filing (presuming it is less than 28k, less than 60k total in 16-17 months).

Regards, JAFO
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"Transfer of assets to a beneficiary do not constitute a taxable gift because the tax code (Section 529) excludes the transfered amount from gift tax provided certain conditions are met."

Then why is there a provision allowing for a larger contribution in a single year (5x the annual exclusion amount) provided that the grandparent files appropriate paperwork allowing accelerated gifting of annual exclusion amount?


Perhaps my choice of words was confusing. Contribution to the 529 is not the same as transfer (distribution) to the beneficiary. The first is subject to gift tax considerations. The second is not, if the rules are followed.

"The "double gift" question rests on whether a contribution to a 529 plan owned by someone other than the donor constitutes a two-step transfer (to the owner and then to the plan) or is a direct transfer to the plan. I think it would be a stretch for the IRS to insist on the two-step interpretation."

This is what I also expected, but then why does a time separation generate a second tax when a simultaneous transaction would not? Is that not elevating form over substance?

I'm not sure I understand your question. Time separation (if you mean parent funding grandparent 529 then acquiring ownership of the plan) generates a second tax because of the change of ownership of the plan. The case where a parent funds a 529 owned by the grandparent shouldn't generate a second tax as that would be elevating form over substance, in my opinion.

Ok. Then if the goal is transfer from the grandparent to the parents before it is used, to avoid reporting it as grandchild's income (and to avoid using any lifetime credit), then I guess the usual rules of gifting apply --- transfer of the annual exclusion amount split over two years (given that is is now September) and to each of the parents of the grandchild . . . 14k in 2011 to one parent (to minimize amount reported on FAFSA filed in January or February 2014) and then 28k to both parents in 2014 after the FAFSA is filed would transfer 42k in within the next 4-5 months. Possible slightly more gifted in 2013 to the second parent if the total amount to be gifted in greater than 42k but less than 56k, or alternatively, simply transfer the amount in excess of 42k in 2015 after FAFSA filing (presuming it is less than 28k, less than 60k total in 16-17 months).

I'm not sure what the objective is here. It's been a while since I've dealt with FAFSA calculations, but my understanding is that any 529 disbursement on behalf of a student is considered student income in the next year's FAFSA calculations regardless of who owned the FAFSA.

The obvious way to game the system is to hold of on using the 529 funds until after the last FAFSA is submitted.

If I've misunderstood something, let me know.

Ira
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irasmilo:

ira {{{"The "double gift" question rests on whether a contribution to a 529 plan owned by someone other than the donor constitutes a two-step transfer (to the owner and then to the plan) or is a direct transfer to the plan. I think it would be a stretch for the IRS to insist on the two-step interpretation."}}}

J: <<<This is what I also expected, but then why does a time separation generate a second tax when a simultaneous transaction would not? Is that not elevating form over substance?>>>

"I'm not sure I understand your question. Time separation (if you mean parent funding grandparent 529 then acquiring ownership of the plan) generates a second tax because of the change of ownership of the plan. The case where a parent funds a 529 owned by the grandparent shouldn't generate a second tax as that would be elevating form over substance, in my opinion."

Let me try again. To simply references, GP refers to Grandparent, PS refers to parents (and a P refers to one of the two parents) and ST refers to the granchild/future college student.

Using 2013 annual exclusion of 14k, let us say that G funds 70k into a 529 plan for ST and with GP as the account owner.

As I understand the rules, that is a gift to the ST, but no gift tax is due (and no lifetime credit) is used if the GP files the proper tax paperwok regarding accelerating annual gifts.

Suppose alternatively, that G funds 70k into a 529 plan for ST and names the PS as the account owner (i.e., not an exsitng account previoulsy established by the PS).

As I understand the rules, that is still a gift to the ST, but no gift tax is due (and no lifetime credit) is used if the GP files the proper tax paperwok regarding accelerating annual gifts.

The double tax concern is whether that is a gift to both the PS and the ST (or only to the ST).

As I understand it, most commentators believe that it is still a gift to the ST, and the GP is not making a 70k gift to the PS, who are in turn making a 70K gift to the ST.

If that understanding is correct, then the time separation question is if a single gift is made when the GP funds a 529 plan naming the ST as beneficiary and the PS as the owner, why does breaking that into two parts, separae in time, funding occuring at one time and later subsequent naming/transferring ownership to PS consitute to separate taxable events? If that is still unclear, then ask again.


J: <<<Ok. Then if the goal is transfer from the grandparent to the parents before it is used, to avoid reporting it as grandchild's income (and to avoid using any lifetime credit), then I guess the usual rules of gifting apply --- transfer of the annual exclusion amount split over two years (given that is is now September) and to each of the parents of the grandchild . . . 14k in 2011 to one parent (to minimize amount reported on FAFSA filed in January or February 2014) and then 28k to both parents in 2014 after the FAFSA is filed would transfer 42k in within the next 4-5 months. Possible slightly more gifted in 2013 to the second parent if the total amount to be gifted in greater than 42k but less than 56k, or alternatively, simply transfer the amount in excess of 42k in 2015 after FAFSA filing (presuming it is less than 28k, less than 60k total in 16-17 months).>>>

"I'm not sure what the objective is here. It's been a while since I've dealt with FAFSA calculations, but my understanding is that any 529 disbursement on behalf of a student is considered student income in the next year's FAFSA calculations regardless of who owned the FAFSA."

The objective is to minimize EFC. Tax evasion is problematic but tax avoidance is perfectly permissible. The United States Supreme Court has stated that "The legal right of an individual to decrease the amount of what would otherwise be his taxes or altogether avoid them, by means which the law permits, cannot be doubted."

Specifically Judge Learned Hand wrote - "Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one’s taxes." Helvering v. Gregory, 69 F.2d 809, 810-11 (2d Cir. 1934).

I believe that same rules apply to the FAFSA. One is free to arrange his or her affairs so that EFC is as low as possible; her or she is not bound to choose a pattern that will make the largest EFC. As I am sure you are aware, there are certains parent assets not reported on FAFSA.


You understanding is not my understanding. My understanding is that college costs paid by the parents are not income to the student. For example, if the EFC from parent assets is $10k and the parents sell 10k of assets outside of a 529 plan, in a non-taxable event, that 10k paid in tuition by the parents for their child is not reported as income by the student the following year on the FAFSA. As I understand the rules, that statement is also true even if the assets are from a 529 plan owned by the parents (and 529 plans owned by the parents are reported on the FAFSA).

44. j. Money received, or paid on your behalf (e.g., bills), not reported elsewhere on this form.

Parent assets are reported elsewhere on the FAFSA Form.

See also: "The amount should include any money paid on the student's behalf by someone other than the student (and his/her spouse) for rent, utility bills, etc., while the student attends school, unless the person making these payments is the parent whose information is reported on this application."

https://fafsa.ed.gov/fotw1112/help/faadef22.htm

"There is no similar question about cash support for parents on the FAFSA because the definition of “Untaxed income and benefits” in the Higher Education Act of 1965 [20 USC 1087vv(b)(1)(F)] is restricted to funds paid to the student or on the student’s behalf, and does not include funds paid to the student’s parents:

(F) cash support or any money paid on the student’s behalf, except, for dependent students, funds provided by the student’s parents;"

http://www.fastweb.com/financial-aid/articles/3673-paying-th...

Under the current rules, I believe that 529 payments made from a 529 plan onwed by the parents do not count as untaxed student income.

"For example, the net worth of the family’s principal place of residence is ignored on the FAFSA, as are any small businesses owned and controlled by the family. Likewise, pensions, 401(k) plans, IRAs and other qualified retirement plans are ignored."

http://www.fastweb.com/financial-aid/articles/2979-which-ass...

See also notes for questions 41 and 42 on the FAFSA form.

"Investments do not include the home you live in, the value of life
insurance, retirement plans (401[k] plans, pension funds, annuities, noneducation IRAs, Keogh plans, etc.) or cash, savings and checking accounts already reported in questions 40 and 88."

Regards, JAFO
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I believe I have my answer:


"Section 529 plans also provide favorable federal estate and gift tax provisions, making them a valuable estate planning tool. There is an accelerated gift option that allows you to average gifts over $13,000 per beneficiary ($26,000 for married couples) over a five year period without incurring federal gift tax. So an individual can contribute up to $65,000 per beneficiary in one year and a couple up to $130,000 per beneficiary without incurring gift tax. [[[NOTE - this was written before recent increase to 14k per year annual exclusion ammount]]] If you give the full amount, you will not be able to give any gifts to the same individual during the five year period without incurring gift tax or using up a part of your lifetime exclusion.

Contributions below the annual gift tax threshold are immediately removed from the donor's gross taxable estate (and included in the estate of the beneficiary). Unlike certain types of trust funds, contributions to section 529 plans are considered a completed gift of a present interest and so are excluded from the donor's gross estate. Contributions above the threshold are included in the donor's gross estate only if the account owner cancels the account or the donor dies during the five year averaging period. If the donor dies during the five year period, the contributions are counted in his or her estate pro-rata according to the number of remaining years, not including the year in which the donor died.


http://www.finaid.org/savings/529plans.phtml


"The following summarizes the impact of section 529 plans on financial aid eligibility:

Section 529 college savings plans are treated as an asset of the account owner, and so have a low impact on financial aid eligibility. College savings plans are reported on the Free Application for Federal Student Aid (FAFSA) as an asset of the account owner, which is typically the parent. Distributions from a college savings plan have no impact on financial aid eligibility (i.e., they are not counted as untaxed income or a resource). [[[NOTE - No longer rue; see below]]]

Section 529 prepaid tuition plans are now treated as an asset and are reported on the FAFSA, just like section 529 college savings plans. The asset value is the refund value of the plan. Distributions have no impact on financial aid eligibility. This change went into effect July 1, 2006. (Previously they were treated as a resource, which reduced need-based financial aid 100%.)

http://www.finaid.org/savings/529plans.phtml


"Previously, if a section 529 college savings plan was owned by someone other than the parent or child (e.g., a grandparent), the plan could be omitted entirely from the financial aid need analysis, affecting neither income nor assets. This loophole, however, was eliminated by the College Cost Reduction and Access Act of 2007 effective with the 2009-10 award year. Such 529 plans are still not reported as an asset on the FAFSA, but any distribution from the 529 plan is reported as untaxed income to the beneficiary, resulting in a severe reduction in eligibility for need-based aid. (This applies only to the FAFSA. The CSS Profile asks the family to list all 529 college savings plans that name the student as a beneficiary, so plans owned by a grandparent but with the student named as a beneficiary would have to be reported.)"

http://www.finaid.org/savings/529plans.phtml

So back to my tax questions (though I doubt any of the foregoign changes the response).

If "contributions to section 529 plans are considered a completed gift of a present interest and so are excluded from the donor's gross estate" even if account is owned by the donor, is the later transfer of wonership also a taxable event?

If yes, as to the entire account value or only the increase in value above the amount originally gifted?

If the entire account value, then the same 14k is being counted twice for gift tax purposes.

Regards, JAFO
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Sorry for posting over myslef, but see also:

http://www.finaid.org/savings/accountownership.phtml

regarding 520 plans owned by grandparents.

Regards, JAFO
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[detailed explanation omitted]

So back to my tax questions (though I doubt any of the foregoign changes the response).

If "contributions to section 529 plans are considered a completed gift of a present interest and so are excluded from the donor's gross estate" even if account is owned by the donor, is the later transfer of wonership also a taxable event?

If yes, as to the entire account value or only the increase in value above the amount originally gifted?

If the entire account value, then the same 14k is being counted twice for gift tax purposes.


I still believe the transfer of the account is a taxable (gift tax) event in its entirety due to the transfer of the rights associated with ownership, but I readily admit that my coclusion is based on logic (always dangerous in taxes) and not any specific experience or review of adjudicated precedents.

Ira
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irasmilo:

<<<[detailed explanation omitted]

So back to my tax questions (though I doubt any of the foregoing changes the response).

If "contributions to section 529 plans are considered a completed gift of a present interest and so are excluded from the donor's gross estate" even if account is owned by the donor, is the later transfer of wonership also a taxable event?

If yes, as to the entire account value or only the increase in value above the amount originally gifted?

If the entire account value, then the same 14k is being counted twice for gift tax purposes.>>>

"I still believe the transfer of the account is a taxable (gift tax) event in its entirety due to the transfer of the rights associated with ownership, but I readily admit that my coclusion is based on logic (always dangerous in taxes) and not any specific experience or review of adjudicated precedents."

Thanks, Ira. I suspected that would be the likely response.

Unless anyone reasonably beleives otherwise or can provide citations to the contrary, I will act accordingly and use the multi-year gifts to both spouses recipient to accomplish the transfer in 2014 and 2015.

Regards, JAFO
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(JAFO31:) So back to my tax questions (though I doubt any of the foregoign changes the response).

If "contributions to section 529 plans are considered a completed gift of a present interest and so are excluded from the donor's gross estate" even if account is owned by the donor, is the later transfer of wonership also a taxable event?

If yes, as to the entire account value or only the increase in value above the amount originally gifted?

If the entire account value, then the same 14k is being counted twice for gift tax purposes.
============
(Ira:)I still believe the transfer of the account is a taxable (gift tax) event in its entirety due to the transfer of the rights associated with ownership, but I readily admit that my coclusion is based on logic (always dangerous in taxes) and not any specific experience or review of adjudicated precedents.

===========
I think otherwise, and I'm basing it on my reading of Prop. Regs. 1.529-5, which I can't link to here because it's from copyrighted reference material with editorial content.

But those proposed regs. do state that the initial contribution to the account is a completed gift, as previously noted.

In addition, Section 1.529-5(b)3) provides that a 529 may have a change in designated beneficiary or transfer to a new account for a different beneficiary within the same family, and that's not a gift either. EVEN THOUGH a new beneficiary is involved.

Unfortunately, I'm frustrated in that these reg. sections do not address the specific issue of change in "ownership", from grandparent to parent, but in this case ownership is a strange concept. The "owner" of the account is really more like a trustee of a revocable trust for the beneficiary, and the contribution to the trust was already a completed gift. The "owner" has no beneficial interest. It's more like you're just changing the trustee of a trust, and that's not a gift.

In fact, it's clear that if the beneficiary dies, the account is included in his/her estate. [Generally not an issue, except for the wealthiest of students.] Conversely, if the donor makes a 5-year annual exclusion election and dies during the 5-year period, the unreported portion of the gift is included in his/her estate.

Bill
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The "owner" has no beneficial interest.

I thought I recalled that the owner could withdraw the original contributions (not the earnings) tax free, but I haven't looked that up. Can anyone comment?

If so, control of the original contributions (where that money could revert to the owner), seems like a beneficial interest. And transferring that ability to withdraw the original contributions to the parent (from the grandparent) would be a gift. (In which case, is the transfer of ownership as a gift only valued at the original contributions?)

I may be all wet on all aspects of this, but I've thought about this on my own before and assumed that's what drove the gift aspect of any such transfer.

fin
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In fact, it's clear that if the beneficiary dies, the account is included in his/her estate. [Generally not an issue, except for the wealthiest of students.]

Hypothetical then -
Grandparent is the owner; beneficiary dies while grandparent is still living. This means that grandparent no longer has the option to change beneficiary because the account is now part of the original beneficiary's estate ?
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Wradical:
============
(Ira:)I still believe the transfer of the account is a taxable (gift tax) event in its entirety due to the transfer of the rights associated with ownership, but I readily admit that my coclusion is based on logic (always dangerous in taxes) and not any specific experience or review of adjudicated precedents.
===========
"I think otherwise, and I'm basing it on my reading of Prop. Regs. 1.529-5, which I can't link to here because it's from copyrighted reference material with editorial content."

Thanks for the reference.

I foudn te following:

http://www.actec.org/Documents/misc/Pacenta529.pdf

page 1 - IRS issued proposed regulations under Section 529 in 1998, which remain proposed regulations today. Taxpayers are entitled to rely on them for taxable years ending after August 20, 1996.

Page 8 -


5. Change of Account Owner Other than at the Death or Incapacity of the Account Owner

a. It is not clear whether the Congress intended to permit the account owner to be changed other than at the death or incapacity of the current account owner. The proposed regulations do not address the ability to change the account owner.

b. Each plan has its rules regarding the ability to change the account owner. Some plans do not permit changes prior to the death or incapacity of the current owner.

. . .

d. Transfer tax consequences of a change in account ownership

(1) Because a gift is made when a Section 529 plan account is established, there should be no further gift tax consequences to a change in the account owner.

(2) However, the account owner controls the distributions from the account, as well as the identity of the designated beneficiary, and can return the account. Under traditional gift tax principles, the termination of such control over the account balance should be a gift.

IOW, no real guidance, and split opinion sbetween professionals.

Proposed Regs. at http://www.irs.gov/pub/irs-regs/10617797.pdf

Regards, JAFO
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JAFO,

As I said earlier, my conclusion was based on logic and not knowledge of specific guidance. Wradical pointed you to regs which address the issue, albeit not conclusively. The only thing left now is see if the Tax Court has weighed in on the matter. Otherwise you're left to your own risk assessment of the course of action you choose.

Ira
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my conclusion was based on logic

I thought we were supposed to suspense logic with respect to the tax code.
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I thought we were supposed to suspense logic with respect to the tax code.
===========================
Oh, being logical is like being creative. You can always TRY it. Doesn't mean it will work.

And telling a revenue agent "That's not logical." is just about as pointless as saying "That's not fair!"

Bill
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my conclusion was based on logic

I thought we were supposed to suspense logic with respect to the tax code.


I made that point explicitly in my original response.

Ira
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