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About GiftLaw Pro GiftLaw Note: In Rev Rul 82-105, a donor created a charitable remainder annuity trust The included amount was calculated as the annual adjusted annuity, divided by the applicable interest rate (now the Sec 7520 rate)
Rev. Rul. 1982-105 - CharitablePlanning. com The holding of this ruling applies only to the portion of the value of a charitable remainder annuity trust that is includible in the gross estate under section 2036
TD 9181. doc - Internal Revenue Service the application of Rev Rul 82-105 (1982-1 C B 133) In addition, several commentators requested guidance regarding the application of section 2035 if the grantor dies within three years after termination of the term of the GRAT (or grantor retained unitrust (GRUT)) These suggestions were not adopted
ALI-ABA Course of Study - Bessemer Trust Cf Rev Rul 82-105, 1982-1 C B 133 (describing the portion of a charitable remainder annuity trust that is included in the gross estate under section 2036(a) as the amount of principal required to produce the annuity payment in perpetuity at the applicable section 7520 rate)
Rev. Rul. 82-133 | Tax Notes This treatment will be allowed for such interest attributable to reserve accumulations existing on June 21, 1982, and subsequent reserve accumulations resulting from excess interest that are allocable to the June 21, 1982, reserve accumulations
Federal Register Vol. 74, No. 82 Thursday, April 30, 2009 . . . - GovInfo Rul 76– 273, 1976–2 C B 268, and Rev Rul 82– 105, 1982–1 C B 133 See §601 601(d)(2)(ii)(b) Under this methodology, the portion of the corpus of a GRT or a CRT includible in the decedent’s gross estate under section 2036 is that portion of the trust corpus necessary to generate a return
Revenue Rulings - GiftLaw Pro - Rutgers University Foundation This revenue ruling amplifies Rev Rul 82-38, to provide guidance to trustees so that provisions can be made in the Declaration of Trust for selection of an alternate charitable remainderman in the event that the designated public charity goes out of existence or loses its qualification
Washington Update with Cases - Bessemer Trust Cf Rev Rul 82-105, 1982-1 C B 133 (describing the portion of a charitable remainder annuity trust that is included in the gross estate under section 2036(a) as the amount of principal required to produce the annuity payment in perpetuity at the applicable section 7520 rate)
Commissioner v. Tufts | 461 U. S. 300 (1983) | Justia U. S. Supreme Court . . . Under his view, there was a transfer of the property for $1 4 million, and there was a cancellation of the $1 85 million obligation for a payment of $1 4 million The former resulted in a capital loss of $50,000, and the latter in the realization of $450,000 of ordinary income
FEDERAL STATUTORY AND LEGISLATIVE CITATIONS - LLSDC Concurrent resolutions must clear both chambers but not the President Ex: H R Con Res 133, 94th Cong (1975) (enacted) [Bluebook Rule 13 2(b)] House and Senate documents generally come from the Executive branch