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Articles by Thomas Gray
Rolling Over and Section 704(c); What’s the Big Deal? - Part 4: The Remedial Method
In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule.
Rolling Over and Section 704(c); What’s the Big Deal? - Part 3: The Traditional Method With Curative Allocations
Continuing with our series on the implications of the application of Section 704(c), the below discussion addresses the use of the traditional method with curative allocations. In Part 1 [insert link] we gave a broad overview of Section 704(c) and its application to property that is contributed to a partnership, where the contributor’s tax basis in the property differs from the fair market value of the property (the built-in gain or built-in loss).
Rolling Over and Section 704(c); What’s the Big Deal? - Part 2: The Traditional Method
In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner.
Rolling Over and Section 704(c); What’s the Big Deal? - Part 1: The Basics
When entering into a partnership agreement where one partner is contributing cash and another partner is contributing appreciated property, inevitably, a tax advisor is going to ask, which Section 704(c) allocation method does the partnership want to use? For the business folks, this may lead to some head scratching and the ultimate question of why would I care?
Recent Tax Court Case Supports Expansive Reading of Service Condition Requirement and Tiered Partnership Structures for Profits Interests
On May 3, the U.S. Tax Court issued a ruling in ES NPA Holding, LLC v. Comm’r of Internal Revenue, T.C.M. (RIA) 2023-055 (T.C. 2023) in favor of the taxpayer petitioner, holding that the limited liability company interest received by the taxpayer constituted a “profits interest” under Revenue Procedure 93-27, 1993-2 C.B. 343 (Rev. Prov. 93-27).
FIRPTA and Publicly Traded Corporations
On May 19, 2023 the Internal Revenue Service (IRS) released AM 2023-003 (the Memo or GLAM) holding that the Foreign Investment in Real Property Tax Act’s (FIRPTA’s) 5% publicly traded exception (the 5% exception) applies at the partnership level and not at the partner level, potentially subjecting the partnership to additional reporting and withholding requirements with respect to its non-U.S. partners, and subjecting the non-U.S. partner to U.S. federal income taxes and reporting obligations.
Ode on the Death of a Favourite Cat Drowned in a…
’Twas on a lofty vase’s side, Where China’s gayest art had dyed The azure flowers that blow; Demurest of the tabby kind, The pensive Selima, reclined, Gazed on the lake below. Her conscious tail her joy declared; The fair round face, the snowy beard, The velvet of her paws, Her coat, that with the tortoise vies, Her ears of jet, and emerald eyes, She saw; and purred applause.
Local governments — all but one of them — want more money from you in increased property taxes - The Citizen
No matter where you live in Fayette County — city or county — if you own property, you will be paying more in property taxes this year as compared to last year. The local governments are holding public hearings in the next two weeks to get taxpayer input on the mainly double-digit percentage increases in your property tax bills.
Ode on a Distant Prospect of Eton College
Ye distant spires, ye antique tow'rs, That crown the wat'ry glade, Where grateful Science still adores Her Henry's holy Shade; And ye, that from the stately brow Of Windsor's heights th' expanse below Of grove, of lawn, of mead survey, Whose turf, whose shade, whose flowr's among Wanders the hoary Thames along His silver-winding way.
If you took Georgia's 2019 pesticide training, not required in 2020
Brad Haire Since UPW programs began in 2015, there is now an aggressive approach to train pesticide applicators intensely for dicamba, paraquat and insecticides.
One Man Dead After Shooting in Hampton
A man is dead after a shooting took place Friday at the McDonald’s near Highway 19E in Hampton, Tennessee. Carter County Sheriff’s deputies were called to the scene around 4:25 p.m. They found a deceased white male and the suspected shooter still in the parking lot. Sheriff Dexter Lunceford confirmed that his deputies have taken the suspect into custody. He said the suspect surrendered to deputies when they arrived on scene. The investigation is still ongoing.
IRS Proposes New Regulations for Determining Whether Foreign Insurance Companies Are PFICs
Thursday, July 18, 2019 After an initial period of almost 30 years without significant regulatory guidance addressing the statutory exception for foreign insurance companies under the passive foreign investment company (PFIC) regime, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) continued the recent trend of fundamental change in this area with the issuance of a new set of proposed regulations.
Choose Carefully: Thinking Strategically About Venue Amid Mounting Agency Rule Challenges
E. Barrett Prettyman courthouse in Washington, D.C. March 22, 2018. Photo: Diego M. Radzinschi/ALM. The D.C. Circuit is thought of as the epicenter of federal administrative law. Due in part to this reputation, it has become the default forum for petitioners challenging agency rules or adjudications. But the traditional view that the D.C. Circuit should be the forum of choice for petitioners challenging agency action is ripe for re-examination.
Elegy Written in a Country Churchyard
The curfew tolls the knell of parting day, The lowing herd wind slowly o'er the lea, The plowman homeward plods his weary way, And leaves the world to darkness and to me.
Assembly Instructions for Lt. Durham’s Honor Route
Carter County Sheriff’s Office (Drug Tip) We at the Carter County Sheriff’s Office are dedicated to the eradication of illegal narcotic use and distribution in our county. Your willingness to assist us with this is greatly appreciated. Please include all information you can WHO, WHAT, WHEN, WHERE, HOW, and WHY. This tip form is completely private. To contact our Drug Unit in person please call (423) 543-0000 The Narcotics Officers who monitor this tip line are very interested in your information.
Johnson City businesses and police plan for St. Patrick's day
The co-owners of Barley Water in Johnson City talk and share beers on St. Patrick's Day. (Thomas Gray/WCYB)JOHNSON CITY, Tenn. — People in downtown Johnson City are already out for St. Patrick's day.The day’s festivities include a pub crawl: an event where people can hop between 10 bars and restaurants. Local businesses expect more customers over the weekend."We're anticipating a big crowd this evening,” Barley Water co-owner Adam Gratz said.
Carter County honor guard needs volunteers for military funerals
Five members of the honor guard stand at ease before a military funeral service begins. (Thomas Gray/WCYB)CARTER COUNTY, Tenn. — On Thursday, the honor guard of the Carter County American Legion gave a final salute to a fellow service member who has passed away, but they barely have enough volunteers to do it."16 would be nice,” honor guard commander Kelly Greene said. “That would be a full crew right there.
Bristol High students walk out of class, remembering Parkland victims
Students stand for 17 minutes of silence in honor of the Parkland, Florida shooting victims. (Thomas Gray/WCYB)BRISTOL, Va. — More than 70 students and administrators walked out of classes at Virginia High School. They stood in the gym in silence for 17 minutes, one for each victim in the Parkland, Florida shooting."I didn't think that we were actually going to have that many people,” student leader Izabella Smith said.
Tri-Cities readies for hunting and outdoors seasons
People shop for outdoors items at the Meadowview Convention Center in Kingsport. (Thomas Gray/WCYB)KINGSPORT, Tenn. — Outdoorsmen and women around the Tri-Cities are getting ready for Spring. Many attended the 3B Outdoors National Expo over the weekend in Kingsport.After months of cold weather, hunters, fishers, and outdoors lovers at this expo are ready to start getting outside again.
Sullivan East High students training for firefighter certifications
Some of the students walk into the live burn facility, where they demonstrated their abilities to locate and extinguish a fire. (Thomas Gray/WCYB)SULLIVAN COUNTY, Tenn. — Sullivan County firefighters are training high schoolers to become the next generation of rescue workers.A group of six Sullivan East High students took a first step Saturday toward becoming certified firefighters.
Sullivan County Sheriff candidates talk school security and more at forum
The candidates for Sullivan County Sheriff (left to right): Joe Earles (R), Jeff Cassidy (I), Matt Austin (R), Incumbent Wayne Anderson (R). (Thomas Gray/WCYB)School security and jail overcrowding were among the hot topics at a Friday forum for Sullivan County Sheriff hopefuls.The campaign features three republicans, including the longtime incumbent, and an independent candidate.
WWII veteran shares how he survived the worst US naval disaster in history
Edgar Harrell shares his story of how he survived the sinking of the USS Indianapolis and the dangers that followed. (Thomas Gray/WCYB)ELIZABETHTON, Tenn.
ETSU theater program helping children with disabilities
Will Gott (left) and Joy Blair (right) sing in front of the group. (Thomas Gray/WCYB)JOHNSON CITY, Tenn. — A special program in Johnson City is helping people with disabilities learn theater skills.The Power of Performing Arts program, which is run by East Tennessee State University, allows children with and without disabilities to come perform in front of others.Will Gott has been part of the power of performing arts class since it began.
No more appeals for Bristol killer, petition for new trial withdrawn
Franklin Delph exits the courtroom in Blountville after withdrawing his post-conviction petition. (Thomas Gray/WCYB)SULLIVAN COUNTY, Tenn. — No more appeals or petitions will be allowed for a convicted killer from Bristol. Thursday in court, 59-year-old Franklin Lee Delph withdrew his post-conviction petition for a new trial.In 2015, Delph took a plea deal for second-degree murder for shooting and killing his wife, Sue Dobbins Delph.
School bus driver charged with falling asleep at the wheel; parents worried by crash
The bus that crashed on Cherokee Mountain Road, in the shop for post-crash inspection. (Thomas Gray/WCYB)WASHINGTON COUNTY, Tenn. — Washington County, Tennessee school bus driver Lanty Lindley is accused of falling asleep at the wheel, leading to a Tuesday afternoon crash that sent five students to the hospital, according to the Tennessee Highway Patrol.It happened in the 400 block of Cherokee Mountain Road near Jonesborough.
Tennessee legislation to ease concealed carry restrictions
A sign at Sen. Jon Lundberg's workplace in Bristol, TN welcomes gun owners to carry concealed weapons. (Thomas Gray/WCYB)BRISTOL, Tenn. — As controversy continues over gun laws in the aftermath of the Parkland, Florida shooting, several Tennessee lawmakers want to expand areas where concealed weapons can be carried.Several gun bills are working their way through the Tennessee House and Senate.
Suspect shot by Hawkins County Deputy had criminal record; TBI says
Joshua Babb, 26, was shot and killed by a deputy Thursday evening. (Courtesy of Washington County, Tennessee, Sheriff's Department/WCYB)CHURCH HILL, Tenn. — New information about the Hawkins County man who was shot and killed by a sheriff's deputy last night.According to the Tennessee Bureau Investigation, 26-year-old Joshua Babb had an extensive criminal history. It includes multiple arrests for domestic assault.Deputies were called to the house on Hickory Hills Road for domestic violence.
Eastman finishes year without missing an order; planning safety improvements
Eastman CEO Mark Costa tells audience members about the company's plans for future safety. (Thomas Gray/WCYB)KINGSPORT, Tenn. — Unbelievably, Eastman Chemical Company did not miss a single customer order despite explosions, a fire and a temporary shutdown in October, Eastman’s CEO Mark Costa said.Costa's update to regional government and business leaders today comes four and a half months after the explosions at the company's coal gasification plant.
Elizabethton High drone piloting class takes off
A student holds a drone before piloting it. (Thomas Gray/WCYB)Drones are expected to produce a lot of jobs in the future. For that reason, seven students at Elizabethton High School are working to earn their remote pilot certificates from the Federal Aviation Administration through a special drone piloting class.
Del. Kilgore changes position on Medicaid; House Republicans push for reform and expansion
The Virginia House has revealed a budget that includes Medicaid expansion. (WCYB)BRISTOL, Va. — Delegate Terry Kilgore (R - Gate City) has changed positions and is now leading the push to expand and reform Medicaid in Virginia. House Republicans added Medicaid expansion to the budget Sunday.For years, Republicans have fought against Medicaid expansion under the Affordable Care act.
Sullivan County considering bullet resistant glass in new schools; new amenities
The plan for the new Sullivan County High School near the Tri-Cities airport. (Thomas Gray/WCYB)SULLIVAN COUNTY, Tenn. — Keeping students safe is one of the items Sullivan County school leaders are looking at as they make plans for new schools.That includes the new Sullivan East Middle School. Superintendent Evelyn Rafalowski said the Board of Education has received two proposals for construction of the $20 million middle school.
Bristol, VA schools response to Florida and other mass shootings; beefing up security
School Resource Officer Mike Danser's car remains parked directly by the front door of Highland View Elementary, as a deterrent.
Family of missing Whitetop man still seeking answers
Family, friends, and law enforcement gather in front of the Food City in Damascus, seeking information from the public.
Game day for Kingsport kids with special needs
KINGSPORT, Tenn. — Sports and activities that most kids take for granted can be rare for those with physical or other challenges. The YMCA at Meadowview in Kingsport takes extra steps to meet the need.Rachel Killen's two sons, Ethan and Austin, got introduced to hockey Saturday. Ethan has autism and has been involved in the Kingsport YMCA’s special needs program for six years."Ethan is not one that likes to participate,” Killen said.
Tennessee lawmakers working to legalize Sunday wine and liquor sales
A Food City employee scans a bottle of wine at the store on Virginia Avenue. (Thomas Gray/WCYB)BRISTOL, Tenn. — Tennessee lawmakers are working to make wine and liquor sales legal on Sundays and holidays.They are banned at liquor and grocery stores.
Kingsport school counselors helping kids prevent long term problems
KINGSPORT, Tenn. — Third grader Zymiria Horton has been working with Roosevelt Elementary Counselor Alice Browder for three years now.Zymiria said she sometimes gets frustrated in class."I have a lot of breakdowns,” Zymiria said.
House for homeless veterans to open in Kingsport
The home, located at 371 Blakley Drive, is being renovated to accomodate 15 veterans. (Thomas Gray/WCYB)KINGSPORT, Tenn. — A non-profit received zoning approval Wednesday in Kingsport to open a new 15 bed house for homeless veterans.It will fill a void after the Salvation Army closed a similar program. Male veterans will soon occupy this house as they transition to homes of their own."They can stay here for a number of months,” Community Outreach Director Doug Murray said.
Boy scouts retire flags with continuous campfire
Boy scouts manage the campfire while retiring flags. (Thomas Gray/WCYB)BRISTOL, Va. — Boy Scouts from around the Tri-Cities will retire flags all week in Bristol, Virginia.Nine different scout troops will take shifts and maintain a continuous campfire.
Johnson City couple receives disability friendly Habitat home
Charles Hollowell (far left) and Michelle Bernard (far right) pray after receiving the keys to their new home. (Thomas Gray/WCYB)A Johnson City couple tearfully received a new home Saturday.Volunteers with Holston Habitat for Humanity handed them the keys and welcomed them inside. After applying for a home more than a year ago, Charles Hollowell and Michelle Bernard are now homeowners."I'm very happy,” Hollowell said."Words cannot explain it,” Bernard said.
Restaurants readying for a busy Super Bowl Sunday
A pizza being cut at Valetino's Italian Restaurant & Pizzeria. (Thomas Gray/WCYB)BRISTOL, Tenn. — With the Super coming up on Sunday, local restaurants are getting ready for one of their busiest days of the year.Staff at Valentino's in Bristol, Tennessee said they expect to at least double their profits over the weekend. They will also have double staff to handle the extra demand, among other preparations."We prepare for the wings, things like that,” manager Joyce Oliver said.
Bristol, TN writes 2x more window tint tickets than Kingsport, records show
Tinted rear windows on a truck in Kingsport. (Thomas Gray/WCYB)BRISTOL, Tenn. — Bristol, Tennessee police issued more than double the number of window tint violations than Kingsport officers last year.The citations have been in controversy following the firing of a Bristol officer for citing senator Jon Lundberg's daughter. Officer Phil Kiersnowski covered his body camera microphone and spoke against the department's aggressive enforcement.
Man meets dispatcher who saved his life; fire department receives $10,000
James Arnold hugs Stacey Fioravanti, the dispatcher who saved his life, when he first meets her. (Thomas Gray/WCYB)SULLIVAN COUNTY, Tenn. — A Kingsport man is alive right now thanks to a home security system dispatcher.On November 13 last year, an apparent electrical short caused a fire at James Arnold's home. Arnold was overcome by the smoke and passed out.
TN House bill threatens to ban fraternities and sororities
News Five reporter Thomas Gray talks with Sigma Chi chapter Vice President Tell Walker about House Bill 2042. (Thomas Gray/WCYB)JOHNSON CITY, Tenn.
Kingsport Fire's rope training could save your life; that's why they're state certified
A technical rescue team member checks to make sure the backup line is correctly placed and tied off. (Thomas Gray/WCYB)KINGSPORT, Tenn. — The Kingsport Fire Department became the first in Tennessee to be certified in rope rescue. The department's technical rescue unit uses rope training as the basis for saving people in several types of life or death situations.On Sunday, inside the tower at Fire Station 2 in Kingsport, rookie Zach Helvey took his first turn on the ropes.
Carter County United Way finishing fundraising, goal less than 1/10th of nearby chapters
A volunteer at Area Resource Ministries helps a client receiving food. (Thomas Gray/WCYB)CARTER COUNTY, Tenn. — The United Way of Elizabethton - Carter County is wrapping up fundraising for the 2018 budget, but it is operating on less than a tenth of the money nearby chapters receive in donations.Johnson City and Kingsport had goals this year of $1.8 million and $3.6 million respectively.
Kingsport revising downtown master plan; still seeking public input
A visual of the downtown master plan. City developers will continue to revise it. (Thomas Gray/WCYB)Kingsport will release a new version of its revised Downtown Master Plan, which will determine how the city grows over the next several years.Kingsport has operated under its old plan for the past 20 years.
Warmer weather returns; time to clean the salt off your car
Car being washed in Johnson City. (Thomas Gray/WCYB)JOHNSON CITY, Tenn. — For a week cold temperatures, snow and ice kept many people in the Tri-Cities, indoors.
Sullivan County man charged with murdering mother of three
LaKeesha Neece, 27, who was found dead in her home January 18. (WCYB)A Sullivan County man has been arrested and charged with the first degree murder of his wife.Deputies said 30-year-old Randall Neece attempted to smother his wife with a shower curtain, then strangled her with an electrical cord.Neighbors reported hearing gunshots before deputies arrived and arrested Randall Neece.
Car break ins plaguing YMCA's; Kingsport to increase security at Meadowview YMCA
The parking lot of the YMCA near Meadowview in Kingsport. (Thomas Gray/WCYB)YMCA’s in Kingsport and Erwin had several break ins to their patrons’ cars Thursday and Friday.Thieves in Kingsport made off with thousands of dollars’ worth of cash, purses, credit cards, and wallets, according to a police report.
Bristol church celebrates Martin Luther King Jr.'s life and legacy
BRISTOL, Va. - Lee Street Baptist Church in Bristol, Virginia celebrated the life of Rev. Dr. Martin Luther King Jr. The service included churches from across the city. "Most of the churches are a part of it,” Pastor Willis Johnson said. “They come and they celebrate. We celebrate the life of King, and his ministry and his contribution." The service included singing, prayer, and a special message encouraging people to continue King's work.
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