The yearlong competition culminates in a joint concert at the New City Brewery in Easthampton at 8 pm. The Valley Music Showcase, a bi-monthly juried live music competition featuring artists from the Pioneer Valley/Springfield/Hartford area, will present five bands on Friday, all of which excelled in previous competitive rounds this year. “Briana and I look forward to pursuing the various threads of conversations that we left off on.” The exhibit includes more than 150 pieces of encaustic, oil painting, photography, video, sculpture, and textile art. “I think the most significant element of any collaboration is the support of your partner's ideas and encouraging them to bring those concepts to fruition,” he said. Taylor, whose work alternates between painting and textile arts with a focus on modern quilting and design, says the two exhibits are “intentionally, and in many ways, subliminally connected." Derose produces multi-media work with encaustic, charcoal, photographics, and video to explore the theme of Polarity. 18.Two artists and partners with Valley roots, Jeff Derose and Briana Taylor, have a joint exhibit at Hampden Gallery at UMass Amherst through Dec. But the court agreed that the entire $10 million was taxable in her estate, without any valuation discounts for her partnership interests. 2043(a) of the Internal Revenue Code - that the IRS improperly double-counted the assets Nancy Powell contributed to the partnership and the value of the limited partnership interests she received in return. That went too far for the Tax Court, which concluded - in a novel application of Sec. The Internal Revenue Service asserted nearly $9 million in estate and gift taxes on the $10 million transaction. ![]() His mother contributed $10 million to the partnership her children contributed only promissory notes. A week before his mother’s death in 2008, Jeffrey Powell established a limited partnership with himself as general partner and his mother as holder of a 99 percent limited partner interest. 3d 1269.Īnother Deathbed Strategy Goes Belly-Up. In so doing, the court ruled, he opened the door for the IRS to re-examine everything in his returns for the years in question, to establish whether Hamilton actually overpaid his taxes even if he won his claim for the charitable gifts. After his administrative appeal was denied, Hamilton paid the tax and sued for a refund in U.S. In 2009, while administratively appealing the IRS assessments, he signed a waiver of the statute of limitations that restricted the IRS examination to his charitable contributions. Robert Hamilton got into a dispute with the Internal Revenue Service over the deductions he claimed for charitable contributions between 20. However, the agency still refuses to grant refunds for any tax that was paid in years for which the deadline for filing claims has passed. In Notice 2017-15, the IRS authorized members of same-sex couples to recompute their lifetime transfer tax exemptions to reclaim amounts consumed in what should have been taxfree transfers to spouses. After Windsor, the IRS accepted amended returns for periods in which the statute of limitations had not expired but granted no relief for earlier transfers. ![]() ![]() Between those two dates, same-sex couples were denied the favorable treatment that spouses receive for gift, estate and generation-skipping transfer taxes. Same-sex marriage arrived in the United States in 2004 when Massachusetts first allowed it, but such unions were not recognized by the Internal Revenue Service until after the Supreme Court’s 2013 ruling in United States v.
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