Modified Trust’s Deduction for Charitable Contributions to Private Foundation Disallowed
Author: Katherine E. David.
Source: Volume 16, Number 03, March/April 2017 , pp.14-15(2)
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Abstract:
In Chief Counsel Advice (CCA) 20165103, the IRS takes the position that a modified trust is not entitled to a deduction under IRC §642(c) unless the modification is the result of a court’s resolving a conflict. In this article, we look at how, in order to get to this holding, the IRS used an expansive reading of existing authority.Keywords: Permissible deduction under §642(c)(1); Crown Income Charitable Fund v. Commissioner; Brownstone v. United States
Affiliations:
1: Strasburger & Price, LLP.