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Old 09-02-2008, 04:48 AM
Alan
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Default Re: demutualization

Mark Bole wrote:
- quote -

> 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/...sher080608.pdf

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<< ------------------------------------------------------- > << 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. > << ------------------------------------------------------- >
 
Old 09-02-2008, 12:23 AM
Mark Bole
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Posts: n/a
Default Re: demutualization

Benjamin Yazersky CPA wrote:
- quote -

> 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. > << ------------------------------------------------------- >
  #-1  
Old 09-01-2008, 11:52 PM
Benjamin Yazersky CPA
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Posts: n/a
Default demutualization

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?



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--
<< ------------------------------------------------------- > << 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. > << ------------------------------------------------------- >
 

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