Thursday, January 22, 2015
Kerry A. Ryan (Saint Louis), Merger is Indirect Gift in Cavallaro, 146 Tax Notes 139 (Jan. 5, 2015):
In Cavallaro v. Commissioner, [T.C. Memo. 2014-189,] the Tax Court held that a merger of two family-owned businesses resulted in a substantial taxable gift. The taxpayers avoided penalties by demonstrating that they relied in good faith on the mistaken advice of competent tax advisers.