Thursday, March 27, 2014
The U.S. Tax Court recently released its decision in the Aragona Trust case.
The court held that:
- A trust can qualify for the IRC § 469(c)(7) exception;
- A trust is capable of performing personal services within the meaning of IRC § 469(c)(7);
- Services performed by individual trustees on behalf of the trust may be considered personal services performed by the trust; and
- The Aragona Trust materially participated in real-property trades or businesses.
Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.