In field service advice, the IRS has concluded it needs more information to determine whether taxpayers may deduct a contribution of a portion of their cooperative housing shares and a proprietary lease to rent their cooperative apartment to a public charity. This is must reading for beginning gift planners and great review for experienced planners alike as this 35-page document provides concise descriptions and case law regarding the partial interest rule, assignment of income and step transaction doctrines, valuation issues, and application of the Section 121 capital gain exclusion.
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