Andrea Zakko


Andrea C. Zakko is an associate at Withers Bergman LLP in New Haven.

IRS Issues DING Guidance
A series of private letter rulings indicate that the IRS is developing a more positive attitude towards properly structured DING trusts.
Deductibility of Claims Against an Estate
In Riegels v. Commissioner (In re Estate of Saunders),1 the U.S. Court of Appeals for the Ninth Circuit addressed whether it was proper for the Tax Court to disallow a $30 million deduction claimed by the estate of Gertrude Saunders for a lawsuit that was pending at the time of Gertrude’s death.
Estate Taxes Aren’t Recoverable Under New Jersey Wrongful Death Statute 
In Beim v. Hulfish, the Supreme Court of New Jersey determined for the first time that federal estate taxes didn’t constitute pecuniary injuries under the state’s wrongful death statute and, therefore, couldn’t be recovered by a decedent’s heirs.
IRS Approves Judicial Reformation of a NIMCRUT
In a recent private letter ruling, the IRS addressed whether the judicial reformation of a net income makeup charitable remainder unitrust was in conformance with final Treasury regulations published after the creation of the trust.
Taxpayer Challenges IRS Denial of Charitable Deduction for Conservation Easement
In Pesky v. United States, the federal District Court of Idaho addressed whether a charitable deduction claimed in connection with the contribution of a conservation easement should be denied because the contribution was part of a larger quid pro quo transaction.
PMRT Arises Due to Failure to Respect Trust Formalities
United States v. Tingey, (10th Cir., May 29, 2013) illustrates the importance of respecting trust formalities.
Charitable Deduction Denied 
In Evenchik v. Commissioner, T.C. Memo. 2013-34 (Feb. 4, 2013), the taxpayers donated approximately 72 percent of their shares in a corporation called Chateau Apartments, Inc., to a non-profit housing organization. The issue addressed in the case was whether the taxpayers submitted a qualified appraisal for the charitable deduction carryforward claimed on their 2006 return.
The Meaning of “Reasonable Cause”
In a recent decision, a Massachusetts federal court upheld the Internal Revenue Service’s assessment of penalties when, based on the advice of its accountants, an estate didn’t file a timely estate tax return.
Taypayer Runs Afoul of Early Distribution Rule
The Tax Court recently addressed whether a taxpayer must pay an additional 10 percent income tax on distributions he received from his qualified retirement plans, despite the fact that the funds were subsequently used to pay court-ordered alimony to the taxpayer’s former spouse.
Tax Deduction Denied for Yacht Expenditures
Andrea C. Zakko reports on a recent court decision and why it's not always wise for lawyers to throw everything but the kitchen sink into their claims.
Survey Reveals Insight into Gifting Options for High-net-worth Individuals
Andrea Zakko reports on the results of a recent study that advisors to high-net-worth clients may find enlightening.
Cautious Appraisals Required for Donations of Conservation Easements
Andrea Zakko reviews the Tax Court's recent opinion on donations of conservation easements.
Estate Tax Plays Role in Calculation of Damages
Andrea C. Zakko highlights the decision in Beim v. Hulfish
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