The Texas Society of CPAs’ Federal Tax Policy Committee, last Thursday, issued a letter to Internal Revenue Service Commissioner Doug Shulman and Chief Counsel William Wilkins requesting interim guidance for the deductibility of expenses paid by a trust under IRC section 67(e).
The IRS issued interim guidance in Notice 2008-32, 2008-116 and most recently in Notice 2010-32 that applied to taxable years beginning before January 1, 2010. The IRS and Treasury Department expect to issue regulations under section 1.67-4 consistent with the U.S. Supreme Court’s holding in Knight v. Commissioner. The TSCPA committee requested that IRS extend the interim guidance until the regulations are issued.
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