demutualization

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Subject Author Date demutualization Benjamin Yazersky CPA 09-01-2008  Re: demutualization Mark Bole 09-01-2008  Re: demutualization Alan 09-02-2008
Posted by Benjamin Yazersky CPA on September 1, 2008, 7:52 pm Please log in for more thread options there was a recent court case where an ins co demutualized & gave the taxpayer shares of stock in the ins co taxpayer sold the stock-the issue went to court IRS said zero basis taxpayer said basis=value upon demutulaization don't have link to the case-but here is an article describing it http://www.nysscpa.org/home/2008/808/4week/article3.htm taxpayer won & IRS may appeal anyone filing refund claims for open years? -- ___________________________________ <<< Benjamin Yazersky, CPA [NJ & NY] >>> -----> real address on hobokeni or hobokenx <----- "This written advice was not intended or written to be used, and it cannot be used by any taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer." (The foregoing legend has been affixed pursuant to U.S. Treasury Regulations governing tax practice.) The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from any computer. -- << ------------------------------------------------------- >> << The foregoing was not intended or written to be used, >> << nor can it used, for the purpose of avoiding penalties >> << that may be imposed upon the taxpayer. >> << >> << The Charter and the Guidelines for submitting posts >> << to this newsgroup as well as our anti-spamming policy >> << are at www.asktax.org. >> << Copyright (2007) - All rights reserved. >> << ------------------------------------------------------- >> Posted by Mark Bole on September 1, 2008, 8:23 pm Please log in for more thread options Benjamin Yazersky CPA wrote: > there was a recent court case where an ins co demutualized & gave the > taxpayer shares of stock in the ins co > > taxpayer sold the stock-the issue went to court > IRS said zero basis > taxpayer said basis=value upon demutulaization > > don't have link to the case-but here is an article describing it > > http://www.nysscpa.org/home/2008/808/4week/article3.htm > > > taxpayer won & IRS may appeal > > anyone filing refund claims for open years? As a cross reference, there was a thread on this same topic started by "Bill" on Aug. 25. -Mark Bole -- << ------------------------------------------------------- >> << The foregoing was not intended or written to be used, >> << nor can it used, for the purpose of avoiding penalties >> << that may be imposed upon the taxpayer. >> << >> << The Charter and the Guidelines for submitting posts >> << to this newsgroup as well as our anti-spamming policy >> << are at www.asktax.org. >> << Copyright (2007) - All rights reserved. >> << ------------------------------------------------------- >> Posted by Alan on September 2, 2008, 12:48 am Please log in for more thread options Mark Bole wrote: > Benjamin Yazersky CPA wrote: >> there was a recent court case where an ins co demutualized & gave the >> taxpayer shares of stock in the ins co >> >> taxpayer sold the stock-the issue went to court >> IRS said zero basis >> taxpayer said basis=value upon demutulaization >> >> don't have link to the case-but here is an article describing it >> >> http://www.nysscpa.org/home/2008/808/4week/article3.htm >> >> >> taxpayer won & IRS may appeal >> >> anyone filing refund claims for open years? > > As a cross reference, there was a thread on this same topic started by > "Bill" on Aug. 25. > > -Mark Bole > I posted the link to the Claims Court case on 8/11. http://www.uscfc.uscourts.gov/sites/default/files/ALLEGRA.Fisher080608.pdf -- << ------------------------------------------------------- >> << The foregoing was not intended or written to be used, >> << nor can it used, for the purpose of avoiding penalties >> << that may be imposed upon the taxpayer. >> << >> << The Charter and the Guidelines for submitting posts >> << to this newsgroup as well as our anti-spamming policy >> << are at www.asktax.org. >> << Copyright (2007) - All rights reserved. >> << ------------------------------------------------------- >> Similar Threads Posted Demutualization (Fisher vs U.S.) October 26, 2009, 11:23 am Demutualization - this year's taxes September 12, 2008, 10:58 pm Selling Prudential demutualization stock August 26, 2009, 2:39 am Lone Accountant wins upset over IRS regarding Demutualization August 25, 2008, 8:14 pm