tam

Jailing Tams for five years at Newcastle Crown Court, Judge Brian Forster told him: "You acted as a bully and took what you wanted from his property and left him in a situation where he had no-one to turn to.

Although arguably Technical Advice Memoranda should not be issued where factual agreement does not exist, TEI recognizes that TAMs serve a valuable purpose in the tax compliance process.

Best Duo: John Kirkpatrick & Chris Parkinson, John Spiers & Jon Boden, John Tams and Barry Coope, Chris While and Julie Matthews Best Group: Bellowhead, Flook Michael McGoldrick Band, Swap.

But Tams, who met his second wife through a lonely hearts internet chatroom, was still married when he and Julie tied the knot.

Chairman Mr Gerald Tams believes Staffordshire companies will be forced into mergers and takeovers to compete on a world markets.

These TAMs are important because they clarify that severance payments made after an acquisition are deductible even when the acquisition was the catalyst for the payments or the payments were coincidental to the acquisition.

The taxable years at issue in the TAMs were 1990-1994, which precede the final conduit financing regulations issued pursuant to Sec.

In one technical advice memorandum (TAM),(19) the IRS addressed this issue in the context of both stock options and stock appreciation rights.

The IRS issued several TAMs challenging the validity of large valuation discounts (e.g., for marketability and minority interests) taken in connection with the gifting of FLP interests.(8) Accordingly, practitioners need to educate clients who implement FLPs that the IRS continues to scrutinize discounts claimed for transfer tax purposes.

As in the three TAMs discussed above, the IRS's argument arose from comparing the post-clean-up value of the property with its pre-clean-up state.

In a reversal from its previous positions in letter rulings, the IRS--in as-yet-unnumbered Technical Advice Memorandum (TAM)--has ruled that proceeds from the sale of unallocated shares held in an employee stock ownership plan's (ESOP's) suspense account resulting from the sale of company stock will be considered earnings and will not constitute Sec.

In Letter Ruling (TAM) 8609005, the IRS stated that gifts within three years of the grantor's death were includible in his gross estate when he was not the only permissible distributee and the trust agreement expressly authorized the trustees to make gifts.

In a yet-unnumbered TAM, the IRS National Office has ruled in a case with extreme facts (terminally ill woman established an FLP after being removed from life support and transferred limited interests to children; a 48% discount was claimed for the remaining limited interests for estate tax purposes) that the existence of a partnership could be disregarded for estate tax valuation purposes.

The IRS National Office has concluded in Letter Rulings, (TAMs) 9540003 and 9527005 that certain payments made to employees in connection with a reorganization are not required to be capitalized under INDOPCO, Inc., 503 US 79 (1992), even though the payments were made as a consequence of and were a condition of the reorganization.

Recent rulings and TAMs in the area of valuation of closely held stock for estate and gift tax purposes appear to indicate that taxpayers may gain an advantage by transferring such stock during life rather than at death.