Jeffrey A. Galant

December 24, 2024 | New York Law Journal

The author writes "While being careful to dot their “i’s” and cross their “t’s” with respect to the complicated rules of section 1256 of the Internal Revenue Code, this attention to detail only took the Wrights so far in their quest to offset substantial capital gains that they had realized in 2002. They apparently gave little thought to section 165(c)’s limitation on an individual’s ability to deduct losses. More about this shortly."

By Jeffrey A. Galant

10 minute read

November 06, 2024 | New York Law Journal

Creditors of corporate entities will, at various times, pursue the controlling shareholders to satisfy an undercapitalized corporation's indebtedness. Following along these lines, when it comes to income taxation, it is always important to be able to identify the proper taxpayer.

By Jeffrey A. Galant

8 minute read

September 27, 2024 | New York Law Journal

A discussion of the unique Tax Court case 'James W. Avery,' where, in connection with promoting his law practice, attorney James Avery attempted to deduct expenditures he incurred as a race car driver.

By Jeffrey A. Galant

7 minute read

August 28, 2024 | New York Law Journal

"Adopting a decision structure which allows for consideration of an independent voice and credible comparability studies should go a long way to building the necessary record," writes Jeffrey A. Galant.

By Jeffrey A. Galant

8 minute read

July 03, 2024 | New York Law Journal

A noteworthy aspect of such planning, and the focus of this article, is the benefit, if any, of planning in advance for the relief from certain federal income tax liabilities potentially available to a married couple who reside together.

By Jeffrey A. Galant

11 minute read

May 10, 2024 | New York Law Journal

Given their druthers, parents generally prefer to treat children equally when it comes to passing on parental property upon death however situations may exist where transfers can be fair and equitable, even though not in equal amounts or shares.

By Jeffrey A. Galant

9 minute read

April 05, 2024 | New York Law Journal

The tools of intelligence (and counterintelligence) gathering, e.g., espionage, spying and the like, have been utilized since time immemorial by states, sovereign and otherwise, for both legitimate and nefarious reasons.

By Jeffrey A. Galant

7 minute read

January 26, 2024 | New York Law Journal

In the annals of family business succession planning, this article discusses some clever, albeit flawed, attempts to transfer ownership interests in a mature enterprise to family members while avoiding the transfer tax toll.

By Jeffrey A. Galant

8 minute read

September 21, 2023 | New York Law Journal

Selling taxpayers often ignore or fail to appreciate the full picture of their sale transaction. This article examines two recent Tax Court cases in which taxpayers incorrectly accounted for the consideration received as sellers of property.

By Jeffrey A. Galant

6 minute read

August 21, 2023 | New York Law Journal

Likely, either the partnership or limited liability company is the most flexible of entities now available for business- or investment-related ventures. Whether either such entity is a partnership for tax purposes is the subject of this note.

By Jeffrey A. Galant

7 minute read