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IRS rules no abatement of first-tier excise tax penalty on private foundation’s undistributed income

In a Technical Advice Memorandum (TAM) 201129050, IRS has determined that the first-tier excise taxes due under Code Sec. 4942 on a trust’s undistributed income for the years at issue shouldn’t be abated under Code Sec. 4962 because the trust failed to establish that it acted with reasonable cause and not with willful neglect.

Beliveau Law Group: Massachusetts | Florida | New Hampshire

The attorneys at the Beliveau Law Group provides legal services for estate planning (wills and trusts), Medicaid (planning and applications), probate (estate and trust administration), business law (formation and operation), real estate (residential and commercial), taxation (federal and state), and civil litigation (in connection with these practice areas). The law firm has offices and attorneys in Naples, Florida; Boca Raton, Florida; Danvers, Massachusetts; Waltham, Massachusetts; Quincy, Massachusetts; Manchester, New Hampshire and Salem, New Hampshire.

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