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Hedge Fund Contribution: No Deduction But No Penalty Either  


Author:  .


Source: Volume 11, Number 03, March/April 2012 , pp.4-4(1)




Family Foundation Advisor

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Abstract: 

Although the applicable legal rule in this case is clear, at least to knowledgeable foundation advisors, it’s hard to avoid feeling sympathy for Mr. Cooperman. He made a $43 million contribution, got little or no deduction for it, and only after what had to be an expensive lawsuit was he able to overcome the $5 million penalty claimed by the government.

Keywords: IRC §170(e)(1)(B)(ii); IRC §6662(a)

Affiliations:  .

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