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Tag: Jerald David August

Acquisitions, Dispositions & Structuring Techniques Corner: Tax Court’s Recent Decision In Mckelvey Est., Affirms Merits Of Deferring Gain Under A Variable Prepaid Forward Contract

By Jerald David August Journal of Passthrough Entities September – October 2017 Edition In McKelvey, the executor of the taxpayer’s estate petitioned for a redetermination of the $41.26M deficiency in income tax for 2008, processed by the IRS, attributable to his entering into various variable prepaid forward contracts (“VPFCs”) with respect to