2013 Year-End Tax
Planning, including
Income, Estate and Gift
Tax Issues
Thomas B. Anthony, CPA - Anthony & Dodge, P.C.
George Cushing, Esq. - McLane, Graf, Raulerson & Middleton,
P.A.
Agenda
Introduction – George Cushing
Income Tax Planning – Tom Anthony
Estate and Gift Tax Planning – George Cushing
Top Tax Considerations for Individuals
and Businesses – Tom Anthony
Questions
2
Introduction
Taxes
Lifetime Gift and Estate Tax Exemption
• 2013 Exemption increased to $5,250,000 – now
“permanent”
• Adjusted for inflation annually (2014 exemption
will be $5,340,000)
• Low gift/estate/GST tax rate: 40%
• Federal Estate/Gift Tax Exemption Portability –
now “permanent”
3
Introduction
2013 Tax Rates will increase for some
taxpayers
• 15% capital gains tax rate and 15% tax rate on
qualified dividends increases to 20% if
taxpayer’s AGI exceeds $400,000 ($450,000 if
married)
• Highest marginal rate increased to 39.6%
• New health care tax on Net Investment Income
3.8% - applied to interest, dividends and
capital gains, as well as income from passive
activities, if taxpayer’s AGI exceeds $200,000
($250,000 if married).
Economy
• Still recovering, but “fragile”.
• Low interest rates continue.
4
Introduction
Low Interest Rates
• Interest rates somewhat higher, but still
historically low
• 7520 rate –
• November 2013 – 2.0% (compare December 2012 –
1.2%)
• AFRs:
Short Term – 0.27% per annum
Mid Term
– 1.73% per annum
Long Term – 3.37% per
annum
• Debt is still cheap. Consider:
• Accelerating large purchases
• Using leverage to develop/enhance cash
reserves
5
Introduction
Uncertainty about 2014 and beyond:
• Republicans still have control of House of
Representatives
• Democrats still have slender majority in
Senate
• Highly polarized political environment
continues
• Difficult to foresee any lessening of
political acrimony
• 2014 Congressional elections may be crucial
6
Individual Tax Planning
American Taxpayer Relief Act of 2012
A.
Individual changes
1.
Individual income tax rates reductions
The 10-, 15-, 25-, 28-, 33-, and 35-percent regular
income tax brackets were made permanent for taxable
incomes below the threshold amount. For taxable
income above the threshold amount, the 39.6-percent
rate, which applied prior to the 2001 law, applies.
The threshold amounts are: (1) $450,000 in the case
of a joint return or surviving spouse; (2) $425,000
in the case of a head of household; (3) $400,000 in
the case of an unmarried person who is not a
surviving spouse or head of household; and (4)
$225,000 in the case of a married individual filing a
separate return. For estates and trusts, the 39.6percent rate applies to all taxable income in the
7
Individual Tax Planning
2. Overall limitation on itemized deductions and the
phase out of personal exemptions
The total amount of otherwise allowable itemized
deductions (other than medical expenses; investment
interest; and casualty, theft, or wagering losses)
will be limited for upper-income taxpayers (this is
called the “Pease” limitation).
Under the Act, the “Pease” thresholds amounts are
modified. The AGI thresholds for taxable years
beginning in 2013 are: (1) $250,000 for single
individuals; (2) $300,000 for married couples filing
joint returns and surviving spouses; (3) $275,000 for
heads of households; and (4) $150,000 for a married
individual filing a separate return. These are higher
than the amounts would have been by merely adjusting
levels from 2001 for inflation. These amounts are
8
Individual Tax Planning
3. Capital gains and dividends
Under the Act, the tax rates in effect before 2013
for adjusted net capital gain and qualified dividend
income are made permanent, except that the 15-percent
rate applies only to adjusted net capital gain and
qualified dividend income which otherwise would be
taxed at a rate below 39.6 percent under the regular
tax. A 20-percent rate applies to amounts which would
otherwise be taxed at a 39.6-percent rate. These
rates apply for purposes of both the regular tax and
the alternative minimum tax.
9
Individual Tax Planning
4. Permanent change in individual AMT
The basic AMT exemption amounts for taxable years
beginning in 2012 were increased retroactively to:
(1) $78,750 in the case of married individuals filing
a joint return and surviving spouses; (2) $50,600 in
the case of other unmarried individuals; and (3)
$39,375 in the case of married individuals filing
separate returns. For taxable years beginning after
2012, the Act permanently indexes the following
dollar amounts for inflation:
i.
The dollar amounts dividing the 26- and 28percent rates
(now $179,500/$89,750 MFS).
ii. The dollar amounts of the basic AMT exemption (now
$80,800/$51,900/$40,400/$23,100, respectively).
10
Individual Tax Planning
5. Marriage penalty
Marriage penalty relief
The Act permanently increases the basic standard
deduction for a married couple filing a joint return
to twice the basic standard deduction for an
unmarried individual filing a single return. It also
permanently increases the size of the 15-percent
regular income tax rate bracket for a married couple
filing a joint return to twice the 15-percent regular
income tax rate bracket for an unmarried individual
filing a single return.
11
Individual Tax Planning
Marriage penalty is back
Single
Married
Medicare Contributor
Tax Threshold
$250,000
Tax Bracket
28%
$146,400
33%
223,050
35%
398,350
39%
450,000
Capital Gains
to 20%
$200,000
$
87,500
183,250
393,350
400,000
$400,000
12
Individual Tax Planning
6. Amounts in applicable retirement plans may be
transferred to
designated Roth accounts without distribution
The provision expands the amounts eligible for inplan Roth direct rollover to include amounts that are
not distributable under the plan. Under the
provision, a §401(k) plan (including a thrift savings
plan, or “TSP”), a §403(b) plan, or a governmental
§457(b) plan that includes a qualified Roth
contribution program is permitted to allow
individuals to elect an in-plan transfer of any
amount not otherwise distributable under the plan
from an account that is not a designated Roth account
under the plan to a designated Roth account
maintained under the plan for the benefit of the
individual.
(Employer Plan must allow for the conversion)
13
Individual Tax Planning
7. Tax-free distributions from individual retirement
plans
for charitable purposes
a. Until December 31, 2013, taxpayers who have
attained age 70 ½ may cause funds held in an
IRA to be distributed directly to public
charitable organizations (note that the payment
may not be designated for a Donor Advised Fund)
b. The consequences of such payment are as
follows:
i. the distribution to charity will be treated
as nontaxable to the account owner and will
not be treated as part of AGI nor will it
affect the account owner’s itemized
deductions or alternative minimum tax
calculation;
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Individual Tax Planning
Tax-free distributions from individual retirement
plans
for charitable purposes (continued)
ii.
the charity will not be subject to income
tax on the distribution;
iii. the account owner will be able to treat
the distribution to charity as satisfying the
account owner’s RMD for the IRA for 2013, if the
account owner has not already received the RMD
this year;
iv.
the account owner will not be entitled to
any income tax deduction for the payment to
charity
15
Tax Provisions Expiring in 2013
The Joint Committee of Taxation has listed the
provisions expiring by the end of 2013.
See “Tax Provision Expiring” handout.
16
Windsor v. United States
A. Background
The Supreme Court has held that Section 3 of the
Defense of Marriage Act (DOMA) -- which provided a
federal definition of marriage that limited its scope
for purposes of federal law to a legal union between
a man and a woman, and of a spouse as only a person
of the opposite sex who is a husband or wife -- as
unconstitutional. It did not address Section 2 of
DOMA, which provides that a state is not required to
give effect to any public act, record, or judicial
proceeding of another state respecting a relationship
between members of the same sex that is treated as a
marriage under the laws of another state. It appears
that for the time being, states that do not permit
same-sex marriages are not required to permit them or
recognize them.
Note: The word marriage is critical. The Supreme Court’s
ruling only
17
Windsor v. United States
B. What the decision did
With the overturn of Section 3, many same-sex couples
-- specifically, those legally married (the “state of
celebration”) who are domiciliaries of a state that
recognizes same sex marriages (the “state of
domicile”) -- will have access to the rights and
duties imposed and conferred on married couples and
spouses under federal law.
C. Which laws are implicated
1. Social Security
2. Qualified plan spousal benefits and qualified
domestic
relations orders
3. Availability of spousal rollover IRAs
4. Exclusion of health insurance premium
attributable to spouse
5. COBRA rights
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6. Income tax provisions
Individual Tax Planning
Medicare Contribution Tax
• Imposed on individuals, estates, and trusts
• Tax is equal to 3.8% of the lesser of
• Net investment income (including passive
activities) or
• The excess of MAGI over the threshold amount
• Gross income does not included excluded items
such
as tax exempt bonds or excluded gain on main
home sale
•
19
Individual Tax Planning
Medicare Contribution Tax (cont.)
• Threshold amounts
• MFJ - $250,000
• MFS - $125,000
• HOH/S - $200,000
• (Not indexed for inflation)
• In addition, 0.9% HI tax on employee wages
in excess of stated threshold amounts
• Employer required to withhold
• Spouse’s wages disregarded
20
Individual Tax Planning
Medicare Contribution Tax (cont.)
• Note:
• Investment income = all passive income from
dividends, interest, annuities, royalties,
and rents, net gain from property
disposition
• Taxpayers with both high wages and high
investment income may be hit with both
taxes
21
Individual Tax Planning
Roth conversions
• No income limit for Roth IRA conversions
• Full or partial conversions
• Re-characterization
• Avoid possible hikes in future tax rates
• Change mind before return is filed
22
Business Tax Planning Tips
Acquire business assets in 2013
• Immediate write-off of up to $500,000
(subject to income limit) plus 50% bonus
depreciation
• 15-year Depreciation for Qualified Leasehold
Improvement Property, Qualified Restaurant
Property and Qualified Retail Property
Buy a Vehicle
• 2013 max deduction is $11,160
• 2013 SUV over 6,000 lbs. max deduction is
$25,000 plus 50% bonus on remainder and 20%
remaining cost recovered through normal
depreciation
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Estate and Gift Tax Planning
“Permanent” Federal Transfer Tax Rates
1. In 2013 and hereafter, the estate and gift tax
rate is 40% on transfers in excess of the
exemption amount.
2. The GST tax rate remains equal to the maximum
federal estate tax rate is therefore 40%.
3. Massachusetts estate tax exemption remains at
$1,000,000 with a top rate of 16%; there is no
gift tax in Massachusetts.
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Estate and Gift Tax Planning
Why Act Now
1.
Although federal gift/estate tax
exemptions are now “permanent” these exemptions are
subject to change, depending on which party controls
the congress and/or the White House.
2.
The values of clients assets, particularly
real estate, may still be depressed due to recent
economic downturn and may offer good potential for
appreciation when economic recovery has been
achieved.
3.
Massachusetts clients should, where
feasible, use gifts to
reduce their gross estate
during their lifetime because the Massachusetts
estate tax exemption amount remains at $1,000,000.
Massachusetts does not impose a gift tax, so lifetime
transfers are especially attractive to a
Massachusetts resident. Even a gift shortly before
death can save Massachusetts estate taxes at as high 25
Estate and Gift Tax Planning
Taxable Gifts
1.
The most direct way for a client to take
advantage of the increased gift and GST tax exemption
amount is to make a taxable gift to his/her
beneficiaries, either outright or (preferably), in
trust (in order to take advantage not only of the
2013 gift tax exemption but also the 2013 GST
exemption).
2.
The client will need to consider carefully
how much she is willing to part with and how much she
will need to retain in order to sustain her
accustomed lifestyle, as well as potential future
needs for care in illness or old age.
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Estate and Gift Tax Planning
Taxable Gifts (continued)
3.
If a client is concerned about loss of
income/access to transferred funds and is married,
the client should consider creating a lifetime
irrevocable trust for benefit of his spouse and
children - a spousal Lifetime Access Trust or “SLAT”.
The spouse can also create similar trust for the
client so long as the “reciprocal trust” rules are
avoided. Both trusts can be structured as “grantortype” trusts as to each grantor and both trusts can
be structured to avoid inclusion in grantor’s estate
at death of each grantor.
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Estate and Gift Tax Planning
Taxable Gifts (continued)
4.
Clients with illiquid assets, such as
residential real estate, can still take advantage of
the current exemption:
a)Give residence/vacation property to an
irrevocable trust for the benefit of
appropriate family members (possibly
including donor’s spouse).
b) Donor can rent back the residence upon
payment of market rate rent. This rent can be
set at the high end of the range, if
desirable.
c) All future appreciation in value of residence
will belong to the donee(s).
d) Trust should be structured as grantor-type
trust.
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Estate and Gift Tax Planning
Taxable Gifts (continued)
e) Expected Tax Results of grantor trust
status:
i)
Amounts paid to trust as “rent” will
not be taxable
income to trust or
its beneficiaries
ii) Rent payments should not be treated
as taxable
gifts to the trust;
iii) Items of expense which would be
deductible by
owner (i.e. real estate
taxes) remain deductible by
owner;
iv) No reduction in basis of real
property due to
depreciation.
29
Estate and Gift Tax Planning
Technical Points
1.
Use of reciprocal trusts. Classically,
the “reciprocal trust” doctrine allowed the IRS to
reverse the anticipated estate/gift tax benefits
normally derived from making an irrevocable gift to a
trust for the benefit of others
i)
If grantors - usually husband and wife –
create trusts for the benefit of each other at
the same time and with parallel terms, IRS view
is that each is treated thereafter as the
creator of the trust of which he or she is also
a beneficiary with the result that the assets
of such trust are included in the gross estate
of the beneficiary spouse
ii)
Typical differences relate to the grant of
a power of appointment in one trust (but not in
the other) or making the terms for
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discretionary distribution different
Estate and Gift Tax Planning
Technical Points (continued)
iii. Safer course is not to use such trust;
even if court concludes that trusts are not
reciprocal, cost of defending the estate tax
audit and, possibly, the court proceedings that
follow may be substantial
2.
Trust for spouse only. The planning
preference is to create an irrevocable trust for the
primary benefit of the less wealthy spouse; if the
grantor is concerned about the potential loss of
access to the transferred funds in the event that the
beneficiary spouse should predecease the grantor, the
beneficiary spouse may be granted a power of
appointment which could theoretically be exercised in
favor of a continuing trust for the grantor’s
benefit, if the grantor is then living.
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Estate and Gift Tax Planning
Technical Points (continued)
Legal concerns include:
a) the possible inclusion of the appointed assets
in the grantor’s estate due to “pre-arrangement”
such that the spouse may be considered to have
been acting as the grantor’s agent, resulting in
the application of the retained interest rule of
Code §2036(a)
b) even if there is no pre-arrangement, in
Massachusetts there may be a claim that, because
the grantor’s creditors can reach assets placed
into a self-settled trust and because the exercise
of a power of appointment is treated as if the
original grantor had designated the ultimate
beneficiaries of the appointed property, the
assets in the appointment trust may be subject to
the claims of the grantor’s creditors.
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Estate and Gift Tax Planning
Technical Points (continued)
Legal concerns include:
c)
that being the case, the IRS might argue
that the appointment back for the benefit of the
grantor will result in estate tax inclusion under
Code §2033
d)
this outcome can be avoided by establishing
the irrevocable trust in a jurisdiction that
authorizes the creation of a domestic asset
Protection Trust (“DAPT”) such as NH. If that is
done, the grantor’s creditors cannot reach the
property transferred into the trust, even if the
power of appointment is exercised in further trust
for the benefit of the grantor. And absent prearrangement, that should cause the trust property
to be excluded from the grantor’s gross estate.
e)
Utilizing the 2013 exemption of both spouses:
33
Estate and Gift Tax Planning
Technical Points (continued)
Legal concerns include:
e) Utilizing the 2013 exemption of both spouses:
•
•
Gift - splitting enables one spouse to use the
federal estate tax exemption of both spouses even
though the entire gift is made by only one spouse
Gift - splitting also applies for GST tax
exemption allocation purposes
•
Gift - splitting permits a wealthy donor to give
away $10,240,000 in 2012, assuming that if the
donor’s spouse consents to gift - splitting on the
gift tax return for the year in which the gift is
made. The donor could also make the gift fully
GST tax exempt using gift - splitting
•
This raises no issues if the gift is made to a
trust for the benefit of persons other than a
spouse
34
Estate and Gift Tax Planning
Technical Points (continued)
Legal concerns include:
•
If the spouse is a beneficiary, gift splitting is
permitted but only with respect to the interests
of the beneficiaries other than the spouse and
then only if the interest of those other
beneficiaries is both “ascertainable” and
“severable” from the interests of the spouse
Solutions:
• Limit spouse’s interest in the trust by an
ascertainable standard
• Have each spouse create a non-reciprocal trust
using his/her own exemption (i.e. dispense with
gift - splitting)
• Have each spouse create a DAPT in an “Asset
Protection” jurisdiction grant a named non-adverse
party
• To add beneficiaries from a class which includes
35
Estate and Gift Tax Planning
Other Planning Techniques and Considerations
1. Short-Term GRAT still available:
a) A client with an asset with significant
appreciation potential transfers that asset
to a GRAT with a 2-year term.
b) The GRAT pays to the client an annuity during
each year of the GRAT’s term which is
designed to be actuarially close in value to
the initial market value of the GRAT assets.
c) Assuming the client survives the GRAT term,
any assets remaining in the GRAT at the end
of the term are distributed to the remainder
beneficiaries, either outright or in trust as
specified in the GRAT.
d) Annuity payments can be “back loaded” (i.e.
designed to increase) by up to 20% each year.
36
Estate and Gift Tax Planning
GRAT (continued)
• Example: In December 2013, when the
§ 7520 rate was 1.2%, Connie transferred
$1,000,000 in marketable securities to a
GRAT with a 2-year term. The GRAT paid
Connie an annuity of $509,009.47 in
December, 2013 and will pay her $509,009.47
in December of 2014. Connie’s 2012 taxable
gift with respect to her original transfer
to the GRAT was $0.
• Connie will receive total payments of
$1,018,018.94.
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Estate and Gift Tax Planning
GRAT (continued)
• The amount passing
beneficiaries will
return achieved by
during the two-year
Annual Investment
Remainder
Return
Benefiaricies
10%
$141,080.00
20%
$320,179.00
30%
$519,278.22
to the GRAT’s remainder
depend on the rate of
the assets in the GRAT
term:
Share
of
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Estate and Gift Tax Planning
GRAT (continued)
2. Why the current environment is favorable to
GRATs:
•
Because the § 7520 rate is still relatively
low, it is easier for the return on the GRAT
assets to “beat” the § 7520 rate, thereby
transferring assets to the remainder
beneficiaries free of transfer tax. As
demonstrated by the foregoing table, as the
amount by which the average investment return
exceeds the § 7520 rate increases, so does
the amount passing to the GRAT’s remainder
beneficiaries.
•
The
the
The
the
November, 2013 § 7520 rate is only 2.0%;
lowest rate was 1.0% (in November, 2012).
stock market returns in 2013 have been in
range of 20-25% YTD.
39
Estate and Gift Tax Planning
GRAT (continued)
3. Note what the “Sensible Estate Tax Act
of 2011” would do to GRATs:
•
•
•
Minimum term of 10 years
A “zeroed-out” GRAT would not qualifying as a
GRAT
GRAT annuity amounts could not decline
40
Estate and Gift Tax Planning
B. Sale to Intentionally Defective Grantor
Trust (IDGT)
1. Example of how the strategy works:
a) The taxpayer creates an IDGT and makes a gift of
“seed money” to the IDGT (traditionally at least
10% of the value of the assets which will be sold
to the IDGT).
b) The taxpayer then enters into an installment sale
agreement with the IDGT for the sale of an incomeproducing asset to the IDGT. The value of the
asset is determined by an independent appraiser,
perhaps taking into account a valuation discount.
c) The IDGT uses the seed money to make a down
payment on the purchase of the asset and issues a
promissory note for the balance of the asset’s
value. The note provides for annual payments of
interest with a balloon payment at the end of the
term. The interest is equal to the appropriate
41
applicable federal rate (AFR), which depends on
Estate and Gift Tax Planning
IDGT (continued)
d) Ideally, the asset sold to the IDGT
appreciates and continues to produce income
after the sale, free of gift and GST tax. If
the asset grows faster than the AFR, then the
additional growth is not subject to transfer
tax.
e) The grantor pays the income tax on the IDGT’s
income, which is effectively an additional
“tax-free” gift to the IDGT.
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Estate and Gift Tax Planning
IDGT (continued)
2. Why the current environment is favorable to an IDGT
sale
a) Interest rates remain low, making it easier for
the asset’s appreciation to “beat” the AFR.
The annual mid-term rate (used for a note with
a term between 3 and 9 years) in November, 2013 is
1.73% (interest payable annually).
b) Furthermore, the increased exemption amount makes
it easier for a taxpayer to make the gift of
essential “seed money” to the IDGT.
For example, a married couple can now make a total
“seed money” gift of up to $10,500,000, presumably
enabling a future sale of assets to the IDGT with a
value in excess to $100M.
3. If consequences of Grantor Trust status are changed
(as is currently proposed by Obama Administration),
grantor trusts already in existence and funded to the
extent of the “seed money’ gift are likely to be
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Estate and Gift Tax Planning
C. Qualified Personal Residence Trust (QPRT)
1. A gift to a QPRT always results in a taxable gift,
which is equal the heirs’ right to receive the
residence at the end of the term of retained use
by the client.
2. If a couple wishes to transfer their home to a
QPRT, they may each transfer a 50% interest and
perhaps take advantage of a valuation discount on
each of their interests in the property.
3. A client who could not previously establish a QPRT
because he had used up his lifetime exemption
amount may now reconsider this estate planning
strategy.
4. QPRTs work better in a high-interest environment
than a low-interest environment, so this is a
strategy to keep in mind as interest rates rise.
5. Even in a low interest rate environment, however,
an older client achieves a significant valuation
discount because of the value attributed to the
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Estate and Gift Tax Planning
QPRT (continued)
• Example: Connie, who is 60 years old,
transferred her house, valued at $1,000,000,
to a 15-year QPRT in December 2012, when the
§ 7520 rate was 1.2%. Connie has made a
taxable gift of $590,920. If the applicable
§ 7520 rate were instead 5.0%, Connie’s
taxable gift would be only $339,940.
• Connie’s actuarial interest in this example
is valued at
$409,080 (40.08%). If Connie were 75 years
old, her actuarial interest would increase
to $764,210 (76.421%).
• The value of the gift will be enhanced if
the underlying value of the residence
increases during the term.
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Estate and Gift Tax Planning
D. Low-Interest Loans
1. Example of how the strategy can work:
•
•
•
•
•
An older-generation transferor loans funds to
a younger-generation transferee, documented
by a promissory note bearing interest at the
AFR. For example, an 8-year note signed in
November, 2013 will bear annual interest at a
rate of 1.73% (the mid-term rate for December
2012).
Remember, the applicable AFR depends on the
term of the note:
The short-term AFR applies to a note with a
term of 3 years or less.
The mid-term AFR to a note with a term more
than 3 years and 9 years or less.
The long-term AFR to a note with a term of
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more than 9 years.
Estate and Gift Tax Planning
Low-Interest Loans (continued)
2. Why the current environment is favorable to
intra-family loans:
•
•
The younger-generation borrower can use the
low interest loan to pay down higher-rate
debt or invest in fixed income assets (or in
investments with appreciation potential) that
yield a return higher than the AFR.
Any returns in excess of the AFR will be
retained by the younger-generation borrower
free of gift or estate tax.
47
Top Tax Considerations for
Individuals and Businesses
1. End of Year Gifting Opportunities
2. Business Tax Planning
3. Business Opportunities
4. Plan for Medicare/HI tax
48
1. End of Year Gifting Opportunities
• Use your Annual Exclusion - $14,000/person per year for
2013 and 2014
• Establish 529 Plans
• Consider larger gifting opportunities to take advantage of
increased lifetime exemption amount of $5.25 million in
2013 and $5.34 million in 2014
• Pay medical bills and tuition payments directly to providers
• Year end charitable giving
49
2. Business Tax Planning Issues
• Review executive compensation plans to ensure retention
of key employees
• Document bonus payments
• Adopt 409A deferred compensation plan
• Make deferral election for 2013
• Establish and fund a pension plan
• Accelerate equipment purchases to maximize
depreciation/expense deduction
50
3. Business Opportunities
• Increase basis in partnership or S Corporation to deduct
anticipated loss
• If self-employed – establish self-employed retirement plan
• Hire qualifying workers to obtain work opportunity tax
credits before 2013 ends
• Incur qualified research expenses
51
4. Medicare/HI Planning
• This 3.8% and 0.9% surtax will affect many
higher income individuals
• Make sure clients are aware of it
• Time income and expenses to stay below
threshold amounts
• Use Like-Kind Exchange to avoid Capital
Gains
• Use Installment Sales to spread-out gain
• Move to Tax-Exempt Income
52
4. Medicare/HI Planning (continued)
• Take capital losses
• Use credit cards to prepay expenses
• Dispose of passive activity to free-up
suspended losses
53
Questions?
Thomas B. Anthony, CPA - Anthony & Dodge, PC
George Cushing, Esq. - McLane, Graf, Raulerson & Middleton, P.A
.
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