The Willens Reportsm

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Merger Not A "Disposition" Of Installment Obligation
February 22, 2024
P is the common parent of an affiliated group of corporations. S is a wholly-owned subsidiary of P that was acquired by P in a taxable transaction on Date 1. &n...

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Recent Reports

Taxpayer Did Not Have A "Qualifying Child"
February 22, 2024
Petitioner is the grandmother of A.V. and has been A.V.'s court appointed guardian since 2007. A.V. was not employed during 2020. Petitioner helped A.V. pay for rent, phone...
Whistleblower Need Not Prove "Retaliatory Intent"
February 22, 2024
Congress enacted the Sarbanes-Oxley Act in the wake of the Enron scandal. 18 U.S.C. section 1514A establishes that no employer may "discharge, demote, suspend, threaten, h...
Failure To Report Swiss Account Was A Willful Violation Of FBAR
February 22, 2024
K is a U.S. citizen. In 2008, K opened an interest-bearing account at FB in Zurich. He designated the account as "numbered." He also requested that FB retain, rather...
The Willens Deal Survey February 2024
February 21, 2024
Welcome to this month's summary of deals. Full reports on some of these transactions can be found via the link in the description, or by searching the company name in our database.