Steve Leimberg’s Asset Protection Planning Email Newsletter – Archive Message #389
|From:||Steve Leimberg’s Asset Protection Planning Newsletter|
|Subject:||Alan S. Gassman, Martin M. Shenkman & Joe Cuffel on Campbell v. Commissioner – Tax Court Concludes that the IRS Cannot Reach Assets in an Old and Cold Self-Settled Offshore Trust|
In Campbell v. Comm’r of Internal Revenue, the IRS sought to classify assets that the taxpayer had placed in an offshore trust before the income tax problems arose as being accessible for the purpose of determining his ability to pay a tax judgment in an Offer in Compromise review proceeding. The taxpayer appealed the reasonableness of this determination to the U.S. Tax Court, and Tax Court Judge Kathleen Kerrigan presided over the proceedings and concluded that the IRS abused its discretion in concluding that the assets under the trust would be considered as an available source of payment in an Offer in Compromise.
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