June 27, 2011 | New York Law Journal
Art for Deductibility Sake: Contribution Scheme FailsIn his Estate Planning and Philanthropy column, Conrad Teitell of Cummings & Lockwood discusses the donation of a work of art that has appreciated in value since the time of purchase, and how accuracy-related penalties on the underpayments can result from the disallowed charitable contribution deductions.
By Conrad Teitell
8 minute read
April 26, 2010 | New York Law Journal
Estate Planning and PhilanthropyConrad Teitell, a principal at Cummings & Lockwood, writes that, once again, the House and the Senate have voted to extend a number of tax provisions, a handful of which deal with charitable contributions.
By Conrad Teitell
11 minute read
December 28, 2009 | New York Law Journal
Estate Planning and PhilanthropyConrad Teitell, a principal at Cummings & Lockwood, writes: Some pundits believe President Obama's recent Nobel Peace Prize is a political liability. I won't discuss that possible liability, but I will discuss the potential tax liability of the $1.4 million cash award. Before a taxpayer accepts a Nobel or Pulitzer prize ? or you accept your prize for notarial science ? keep in mind that IRC �61(a) states that all income from whatever source derived is includable in gross income, unless specifically excluded.
By Conrad Teitell
9 minute read
April 23, 2007 | New York Law Journal
Estate Planning and PhilanthropyConrad Teitell, a principal at Cummings & Lockwood, writes that it is easier for a Hummer to go through the eye of a needle, than for an IRA owner's estate to avoid income in respect of a decedent being taxed to his estate when his Individual Retirement Account is used to satisfy pecuniary charitable gifts.
By Conrad Teitell
10 minute read
May 02, 2008 | New York Law Journal
Estate Planning and PhilanthropyConrad Teitell, a principal at Cummings & Lockwood, gives us the rest of the story on one of the most interesting cases to come down the tax pike in a long time. It involved charitable gifts made by way of disclaimer. However, it also dealt with valuation and public policy issues. And it might well determine important issues other than those before the Tax Court.
By Conrad Teitell
12 minute read
August 23, 2004 | New York Law Journal
Estate Planning and PhilanthrophyConrad Teitell, a principal at Cummings & Lockwood, writes that when it comes to the tax law, things aren't always as simple as they first appear. Take the case of a donor who bequeaths his art collection to charity. He gets an unlimited estate tax charitable deduction for the fair market value of the art whether the charity is a public charity or a private foundation.
By Conrad Teitell
8 minute read
April 24, 2006 | New York Law Journal
Estate Planning and PhilanthropyConrad Teitell, a principal at Cummings & Lockwood, writes that whether railroad rights-of-way gifts are deductible or not would seem to be an issue only railroad owners would care about, but a recent Technical Advice Memorandum from the IRS is an excellent primer on the law of retained rights and the so-called so-remote-as-to-be-negligible doctrine. So you don't have to be on the railroad's track to pick up knowledge that can help you in an array of situations.
By Conrad Teitell
10 minute read
April 25, 2005 | New York Law Journal
Estate Planning and PhilanthropyConrad Teitell, a principal at Cummings & Lockwood, tells a tale about a donor, the donor's lawyer and the charity's estate planning director. The plot centers on a mucked-up charitable remainder trust.
By Conrad Teitell
8 minute read
June 26, 2006 | New York Law Journal
Estate Planning and PhilanthropyConrad Teitell, a principal at Cummings & Lockwood, writes that sometimes donors who have created charitable remainder trusts find that they no longer need the income. So they give their remaining life interests to the charitable remainder-organizations, thereby making the entire trust corpus immediately available to the charity. In the process, they get an income tax charitable deduction for the then-current value of the life interest . . .
By Conrad Teitell
8 minute read
August 27, 2007 | New York Law Journal
Estate Planning and PhilanthropyConrad Teitell, a principal at Cummings & Lockwood, unravels a recent trust conunudrum with plot twists and red herrrings worthy of Alfred Hitchcock.
By Conrad Teitell
10 minute read