TaxTrends

Recent Cases
and Rulings

David O’Driscoll, J.D., LL.M.

IN THIS DEPARTMENT

Gross Income

Courier can compute mileage allowance on same basis as compensation: Rev. Rul. 2004-1

Second Circuit includes contingent fee in clients gross income: Raymond, 2d Cir.

Individuals

Separate liability requirements must be met prior to spouses death; Est. of Jonson, 10th Cir.*

Interest Income & Expense

Private annuity not subject to OID provisions: LTR 200352001

Partners & Partnerships 

Partnership retirement payments satisfied SE tax exemption: LTR 200403056

 

The reports of cases, rulings, etc., herein, except for the Reflections, are edited versions of the relevant court opinion, published ruling, etc.

^*This development, concerning related matters, is covered in the Reflections to the report of the principal item.