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Tax

Jun. 28, 2022

Timing: the most important element in tax planning?

Beware: having a long period of time between setting up a structure and executing the strategy is no protection from an IRS challenge.

Bruce Givner

Of Counsel
KFB Rice, LLP

Email: Bruce@KFBRice.com

Columbia Univ School of Law

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Owen Kaye

Managing Partner
KFB Law Group

12100 Wilshire Blvd #245
Los Angeles , CA 90025

Phone: (310) 207-8008

Fax: (310) 207-8708

Email: owen@kfblawgroup.com

Western State Univ College of Law

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Understandably, taxpayers wish to take actions which reduce their tax liability. There are many elements that lead to success in that endeavor. For example, the structure should be firmly based on (i) the Internal Revenue Code; (ii) Internal Revenue Service Regulations, Revenue Rulings, and Revenue Procedures; and (iii) cases decided by the courts.

However, the most famous tax case involved a taxpayer who lost after strictly following the ...

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