Law Commons^™

Fiduciary Income Taxation And The Holloway Adjustment, Dennis E. Bires

Akron Tax Journal

A great deal of the complexity of the rules dealing with income taxation of trusts and estates' can be attributed to the imperfect compatibility of two different regimes of law: the federal taxation of income and local rules of trust accounting. Just as the confluence of two rivers may generate turbulence exceeding that of either branch, the meeting of federal tax law and state trust law in Subchapter J of the Internal Revenue Code generates problems that neither discipline would present by itself.

In 1972, a New York Surrogate's Court introduced the Holloway adjustment to fiduciary accounting. This equitable adjustment …

Death Of A Partner: Pre And Post-Mortem Planning, Jerome Hesch

Akron Tax Journal

There are several alternative techniques which can be employed to alleviate the income tax problems associated with the death of a partner. The sophisticated tax advisor will understand, however, that some of the suggested techniques may not be practical for all situations. The purpose of this article is to describe these planning techniques and to guide the tax advisor as to which technique is appropriate for his client.