Hedge Fund Contribution: No Deduction But No Penalty Either
Author: .
Source: Volume 11, Number 03, March/April 2012 , pp.4-4(1)
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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)
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