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How to Avoid Costly Mistakes in Charitable Planning, Estate
Planning Journal, Feb 2003 |
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Estate Planning
Journal (WG&L) |
CHARITABLE PLANNING
There are a number of pitfalls to avoid when advising clients
about charitable planning. Practitioners should disclose all ramifications of
any contemplated charitable plan and should be sure the plan serves the
clients' best interests.
Author:
VAUGHN W. HENRY, CONSULTANT, AND JOHNI HAYS, ATTORNEY
VAUGHN
W. HENRY is an independent advisor to charitable organizations on planned giving,
and provides training and consulting services on charitable planning. His
consulting firm, Henry & Associates in
This article
highlights specific areas of charitable planning where mistakes seem to
re-occur, based on the authors' experiences as charitable planning consultants.
By discussing real-life mistakes to be avoided, our goal is to
share practical experience and knowledge.
As planners
work together in a team to recommend a charitable plan for clients, it is
imperative to always place the client's interests ahead of the charity, the
attorney, the CPA, and the life insurance agent. It seems like a statement
of the obvious. But sometimes a plan can seem so good, the planner doesn't want
to throw water on the proposal by mentioning the possible disadvantages. The
planners in the following case went a step farther down the wrong path by
intentionally omitting relevant information the donors needed to make an
informed decision.
In Martin
v. Ohio State University Foundation, 1 the donors of a
NIMCRUT (net income with make-up charitable remainder unitrust) sued their life insurance agent,
the life
insurance
company, and the charity
that also acted as trustee of their NIMCRUT. In this case, an attorney and an insurance agent
had recommended to a couple a charitable plan that included the donation of
$1.3 million of undeveloped farmland to a NIMCRUT. The donors would use income
from the NIMCRUT to purchase a $1 million life insurance policy, costing $40,000
per year, for wealth replacement for the donor's children.
The donors
received several proposals over a few months. Each proposal showed the NIMCRUT
paying the donors income immediately after the execution of the NIMCRUT.
Because the donor's annual income prior to the transaction was only $24,000,
the donor was counting on the trust income to pay the insurance
premiums.
The charity's
representative wrote a comment on the last proposal shown to the donors that a
net income trust funded with non-income-producing land can't make any income
payments until after the land is sold. When the insurance agent saw the comment on
the proposal, he deleted it before giving it to the donors. Unfortunately, the
land was not sold until two and one-half years later, and no income was paid to
the donors during that time. In the meantime, the agent tried to loan the
clients enough money to pay the insurance premiums. But eventually, the
policy lapsed. The donors sued for fraud, negligent misrepresentation, breach
of contract, and breach of fiduciary duty on the ground that they had never
been told the truth about income not being payable from the NIMCRUT until after
the land was sold.
In Martin,
the advisors failed to give the donors accurate and complete information as to
how the charitable gift would work in their situation. The advisors
intentionally deceived the clients for what appears to be their own financial
gain. At all times and in all aspects of planning with clients, the goal must be
to provide advice that is in the clients' best interests. Clients deserve
objective, comprehensive, and accurate advice from their planners even if it
prevents the charitable gift from occurring.
Sometimes,
planners recommend a charitable gift as if it were a financial product. But a
charitable gift is not a product; it must be analyzed as part of an integrated
estate and charitable plan. For example, one planner wanted to set up a CRAT
(charitable remainder annuity trust), funded with farmland, for an older
client. The planner had a fixed annuity he wanted to sell to the trustee who
would pay for it using the proceeds from the land. The planner was under the
impression that the trust was required to purchase a commercial annuity because
it was a charitable remainder "annuity" trust. The planner was then
advised that a well-balanced mutual fund might be a more suitable investment
for the proceeds. The planner responded he wasn't licensed to sell mutual
funds.
Upon learning
that the annuity would produce "tier one" ordinary income at the
client's marginal income tax bracket of 42%, the planner replied that because
his client would be obtaining a large income tax deduction, the client could
afford to pay more in income taxes. 2
Sadly, in
this situation, the product-selling planner wasn't mindful of the drawbacks of
recommending a CRT (charitable remainder trust). The planner did not ascertain
his client's charitable interests. Instead, he suggested the CRT as a means to
avoid or even evade capital gains taxes when, in fact, the strategy would
potentially increase his client's tax liability. The recommendations made for
this plan weren't in the client's best interests and could be considered
malpractice on the part of the planner.
Another
misstep can occur when the advisor serves as the trustee for either the
client's life
insurance
trust or charitable trust. Financial planners, brokers, and insurance agents
must be extremely cautious when asked by their clients to serve as trustee. The
best answer to give a client is: "No, thank you." Serving as trustee
can create a serious conflict of interest if the trustee benefits in any way
though any transaction with a charitable entity, not to mention SEC problems if
the agent or broker has a securities license.
If an insurance agent
is selling a policy to the trustee when he also serves as trustee, he is
selling a product to himself for which he earns a commission using someone
else's money. The result is a conflict of interest; it's best to leave the
trustee's duties to a trust professional.
Generally,
non-legal advisors are not well-trained in the duties imposed on the trustee as
a fiduciary. Moreover, non-legal advisors are typically unfamiliar with the
language used in trust documents as well as the implications of a trust's
provisions. Most insurance
companies will not allow their agents to act as trustees for trusts funded with
the insurer's own insurance
policies. Additionally, most E&O (errors and omissions) liability coverage
does not include acts by an insurance agent serving as a trustee.
Even
attorneys are reluctant to be trustees because attorneys know all too well the
complex duties involved when acting as a fiduciary and following the prudent
investor rules. One trust officer, who found out too late what the trustee's
duties are, served as the trustee of a testamentary CRAT. He asked how long he
could wait to begin making payments to the income beneficiaries because the
land held by the CRAT hadn't been sold and there were no other assets in the
trust. Three years later, the income beneficiaries still hadn't received their
first income payment from a trust that has no legal recourse but to distribute
income or assets annually, whether or not those assets are liquid.
Another
difficulty arises when a charitable planner is not familiar with the
consequences of making gifts using various types of assets. The tax rules
governing charitable deductions for different kinds of assets can be complex,
so the best way to prevent these mistakes is to know the rules for each type of
asset. Exhibit 1 lists assets that either should be given with caution or
should not be given at all.
For instance,
one planner suggested that a client donate art worth $3 million to a CRUT that
required a 10% income payment. Even though the client properly executed the
CRUT, the client continued to display the artwork in his home. The planner
mistakenly thought the charity would advance the 10% income payment to the
trust each year. The planner did not know the artwork couldn't be kept
indefinitely on display at the client's home. 3 Furthermore, the
charitable deduction in this situation was not based on the artwork's fair
market value (FMV) (although the planner had told the donor his deduction would
be based on FMV). Instead, the deduction for tangible personal property that
has no "related use" to the CRUT was based on the donor's much lower
cost basis. 4
Another
planner was working with a client whose only assets were $75,000 of mutual
funds and a $350,000 IRA. The planner didn't realize that the entire IRA would
be subject to income taxes and possible penalty taxes if the client donated it
to a charity
in exchange for a charitable gift annuity. 5 Adding to the
misunderstanding was the offending charity's IRA donation "proposal,"
which failed to adequately disclose the disadvantages of using an IRA for an
inter vivos charitable gift under current tax laws. (The proposed Charity Aid,
Recovery and Empowerment Act of 2002 (the "CARE" bill), 6 if enacted into law,
may allow IRAs to be given to charities during the donor's lifetime
without causing a taxable event.)
A financial
planner, who also wasn't aware of the consequences of donating the specific
asset he recommended, knew his client would soon receive a large sum of money
from the sale of a business. The planner recommended that his client quickly
donate the business to a CRT to help his client avoid taxes. Later, the planner
discovered the client had actually sold his entire business five years ago, and
this large sum of money was the final payment in a series of installment
payments for the buyout.
Frequently, a
charitable trust is set up by a financial advisor or insurance agent
with the expectation that the donor, who often serves as trustee, will look to
the advisor or agent to reinvest the proceeds of the donated asset once it's
sold. While there is nothing wrong with this, advisors must be aware of the
complexities associated with the Prudent Investor Rule, charitable trust
accounting, tax deductions, and other charitable rules in order to comprehend
fully the consequences of their recommendations.
An example of
improperly invested CRT assets occurred when a planner proposed that his
middle-aged donor establish a CRAT. Inside the CRAT, the donor-trustee bought a
"life-only"
single premium immediate annuity to "guarantee" the annuity income
payable to the income beneficiary. The flaw in this transaction is that the charity would be
left without any assets when the trust terminates, because a single premium
immediate annuity for "life only" ends upon the death of the
client, with no principal balance left over. The planner's recommendation would
make the trust subject to oversight by the state's Attorney General for
imprudent investment, and all the client's advisors are potentially liable to
the charity.
The planner didn't realize that a CRT is a split-interest gift, and there are
two beneficiary groups with a legal interest in the trust. Hence, the trustee
must wear two hats—one for the income beneficiary and one for the charity.
To compound
an already unpleasant situation, when the planner was told about the flaw in
his proposal, he and the lawyer argued that the trustee's purchase of the
annuity was valid because the trust "passed the 10% test." 7 They didn't
understand the difference between the 10% test in terms of obtaining a
charitable deduction and the subsequent problems inherent in investing CRT
assets improperly.
Another
planner, who also recommended a similar plan, suggested that the trustee
purchase a life
insurance
policy to pay the charity
its portion when the immediate annuity payments end. However, this plan was similarly
destined for failure, because a CRAT cannot accept ongoing contributions to pay
a lifetime of insurance
premiums. 8
Improper
investing occurred when a stockbroker chose to invest his client's CRT funds in
several partnerships, producing unrelated business taxable income (UBTI) in the
first year of the CRT's existence. The presence of UBTI created a taxable CRT
that did not avoid capital gains tax when the appreciated asset that funded the
CRT was sold. 9 In addition, there
was no income tax deduction to offset the reinvestment error, compounding the
harm from the broker's poor advice.
In Bartels'
Trust, 10 the Bartels
established a supporting organization for the University of New Haven. The
Bartels, as trustees, invested in securities using funds borrowed from their
stockbroker. The court found the income derived from securities purchased on
margin was UBTI.
Other mishaps
have occurred when the trustees were given access to a charge card on a money
market account held inside a CRT. When trustees have charge cards on CRT
assets, the outcome can be self-dealing and debt-financed problems similar to
trading on margin accounts and charging the CRT interest on the loan when the
trades do not materialize as expected.
If a planner
recommends ("sells") a CRT as a way to take assets under management
or to sell wealth replacement, it isn't unethical but it can be shortsighted.
It's also likely to result in unhappy clients who find themselves stuck with an
irrevocable plan that doesn't meet their needs. Agents and planners who
recommend charitable gifts must be knowledgeable about charitable gift laws and
be prepared to assemble a team of experts to implement a plan that serves the
donor's best interests.
Learn from
the mistake of an insurance
company that allowed a commercial deferred annuity to be removed from inside a
CRT. The CRT's trustee was the owner and beneficiary of the annuity, and her
husband was the annuitant. At the husband's death, the death claim form was
sent to the surviving spouse, who checked the box on the claim form allowing
the surviving spouse to change the ownership of the annuity to her own name as
an individual. She then withdrew all the interest earnings in the annuity. The
error wasn't discovered until the spouse complained about the large amount on
the IRS Form 1099 that she received the following January for the interest
income she had gotten. This is a problem with NIMCRUTs that use a deferred
annuity when the insurance
company incorrectly sends a Form 1099 to the annuitant, instead of to the
tax-exempt CRT, while the CRT properly issues a K-1 for the same income
distributions, thus doubling the income tax exposure.
The
four-tiered system of accounting in a CRT is complex. 11 When planners do not
fully comprehend all the issues involved, mistakes can be made. For instance,
one attorney advised his client to fund a CRT with farmland. The attorney
recommended that the trustee purchase tax-free municipal bonds after the land
was sold in order to obtain tax-free income from the CRT. What the professional
didn't realize, though, is that the capital gain income from the sale of the
real estate is higher on the four-tier accounting system than any new tax-free
income generated by the municipal bonds. Understandably, the client was quite
unhappy when the income wasn't "tax-free."
Professional
trustees can get into trouble, too. In In re Estate of Rowe, 12 the trustee of a CLT
(charitable lead trust) was replaced via a court order for failing to diversify
IBM stock. In 1989, the decedent in Rowe had established an 8% CLT,
funded with 30,000 shares of IBM stock worth approximately $3.5 million. Eight
years later, the trust still owned 20,000 IBM shares, now worth $1.9 million.
The court noted that the bank failed to follow its own policy manual of
diversification, and ordered the bank to refund its commissions and pay damages
totaling $630,000. The court found that the bank was negligent and had acted imprudently
in failing to diversify the trust's assets immediately upon receipt of the
stock.
A charitable
planning strategy can be effectively implemented with the appropriate
professionals, including the client's attorney, CPA, planned giving officer,
and life
insurance
agent. However, in charitable plans where life insurance is a part of the overall
plan, the purchase of life
insurance
inside an irrevocable life
insurance
trust (ILIT) should be monitored by the donor's estate planning attorney.
Attorneys should direct the process and clearly indicate to the donor, the
trustee, and the insurance
agent how the process should work and in what order each step should occur.
Otherwise, the insurance
sale can be handled in a way that undermines the donor's estate plan. The
following life
insurance
missteps can cost clients hundreds of thousands of dollars in estate or gift
taxes.
The insurance policy
is issued before the life
insurance
trust is established. In this situation, the insurance company issues the policy before
the irrevocable trust is executed and funded. If the policy is applied for
before the trust is executed, the application commonly names the insured as the
policyowner. If the policy is issued with the insured as the owner, and the
ownership is thereafter transferred to the irrevocable trust, Section
2035 causes the policy proceeds to be included in insured's estate if
he or she dies within three years of the transfer.
The preferred
practice is to have the donor's insurability determined using "trial"
applications. But once insurability is approved, the policy should not be
issued until the ILIT is executed and funded, and Crummey withdrawal power
letters have been sent to trust beneficiaries and the Crummey powers lapse.
13 At that point, the insurance agent
submits a completely new application naming the trustee as the owner and
beneficiary. The trustee then pays the premium to the agent, and the policy is
officially issued.
The insurance agent
accepts the premiums directly from the insured and applies those premiums to
the policy owned by the ILIT. The proper procedure requires that the agent
obtain the premium check from the trustee's funds, not from the
insured's personal funds, when the trust beneficiaries have withdrawal powers.
The goal is to have the trust funded, the withdrawal beneficiaries notified,
and the beneficiaries' rights to those annual exclusion gifts lapse before the
trustee pays the premium.
If, on the
other hand, the agent obtains a premium check directly from the donor's
personal funds, the premium amount is not considered a gift of a present
interest because the trustee never had the funds, nor have the beneficiaries
been notified of their withdrawal rights. 14 Therefore, their
gifts cannot qualify for the gift tax annual exclusion. The insured must file a
gift tax return for these gifts and use part of his applicable exclusion amount
(currently $1 million) to cover the premiums. 15
The various
illustrations prepared by charitable planning software are generally given to
prospective donors to describe—via diagrams or flowcharts—the type of
charitable gift being proposed. The mistakes made when presenting these
illustrations arise from a misunderstanding of the variables behind the
illustration. For example, a common mistake is to create a CRT with the donor,
spouse, and child as income beneficiaries, but the illustrations may fail to
mention the loss of the marital deduction and the effect of taxable gifts with
a CRT being included in the grantor's estate. The software produces the correct
"income tax deduction," but does not address the more complex gift or
estate tax issues.
The
charitable planner must know the variables that produced these calculations and
numbers. The planner must understand the footnotes and assumptions behind every
proposal. In the case of a CRT, for example, the planner needs to know what
interest rate is being used to assume the future growth of the CRT assets. In
addition, the interest rate must be a reasonable number. In turn, the planner
must inform the client of the variables used in the illustration. The client
must know what numbers he can rely on and those he cannot. The more the client
knows and understands, the better informed and happier the client will be.
Planners new
to the field of charitable giving may have a misconception about a charitable
gift annuity. Because planners may sell commercial annuities to clients for
commissions, they sometimes assume that a charitable gift annuity is an annuity
offered for sale to the public from their insurance company.
However, a
charitable gift annuity is not a commercial annuity offered by a life insurance
company. It can be offered only by a charity and is an agreement between a donor
and a charity
in which the donor gives an asset in exchange for lifetime income. The income
provided to the donor from the charitable gift annuity is always paid by the charity.
An example of
this misconception involves a young planner who was asked to work with a
particular charity's
donors to conduct seminars and help establish charitable gift annuities. The
planner thought the insurance
company had an annuity for him to sell at the seminar and that he would be
earning a commission on each charitable gift annuity "sold."
To make the
confusion worse, a few charities are under scrutiny for paying advisors a
"finder's fee" for bringing in clients to establish a charitable gift
annuity with the charity.
16 Not only are these practices
considered highly unethical, but they may also be a violation of the
Philanthropy Protection Act of 1995. An advisor does not help a donor fulfill
his charitable objective to donate to causes about which the client feels
strongly if the advisor steers all potential donors to only one charity—the one
that will pay him a finder's fee.
Improper use
of form books or software can generate trouble. One attorney who hurriedly
drafted a trust for his client learned this the hard way after inserting boiler
plate language from a form book. The language gave the trustee of the CRT the
power to pledge trust assets and to borrow funds. Those powers put the
tax-exempt status of the CRT at risk. 17
Another
drafting error occurred when an attorney used the wrong trust form in his word
processing program and drafted a NIMCRUT for his clients instead of a standard
CRUT. When the clients' CPA informed the clients they shouldn't have been
taking a fixed 7% amount, they immediately went to their attorney to see what
went wrong. 18
A different
error occurred when a CRUT was drafted to give all the investment powers to the
"investment counsel" and none to the trustee. Because the Regulations
prohibit restrictions on the trustee's power to invest trust assets, the IRS
found the trust did not qualify as a CRT. 19
One client,
who intended to leave the bulk of her estate to a private foundation controlled
by her family, discovered that the trust was drafted to limit the receiving charity to a
public charity,
thereby eliminating her private foundation as a charitable recipient.
Fortunately, the IRS allowed a reformation to correct the drafting error. 20
In Estate
of Starkey, 21 the lawyer drafted a
testamentary trust for the benefit of a church and a college. Unfortunately,
the language used to describe the church was "missionaries preaching the
Gospel of Christ," which the court found provided for an unspecified class
of beneficiaries and hence did not comply with the requirements of Section
2055 . The document did not contain language or express an intent that
would allow it to qualify for a charitable deduction, and thus, a $1 million
charitable deduction was lost. The decedent's son was the lawyer who did the
drafting, and the court noted that he "never claimed to have any estate or
charitable planning expertise."
The
unauthorized practice of law can be committed by a non-lawyer when that person
provides legal advice to another or prepares or approves legal documents for
others. 22 The unauthorized
practice of law can occur in charitable and estate planning through the misuse
of computerized legal documents also known as "specimen" documents.
23
The reason
for providing specimen documents is so that the planner can bring to the
planning process a "value added service" for the client's attorney.
These sample documents are intended for use by the client's attorney when that
attorney may not be an expert in the field and could use a "starting
point" in drafting. It's a way for the insurance agent to be professional
and helpful in the planning process.
Unfortunately,
these specimen documents can be misused by the planner or the client. Some
non-lawyers have asked if they can "just fill in the blanks" because
their client doesn't want to pay an attorney. Whether it is a specimen ILIT or
a CRT, many costly errors have been made when a non-lawyer or donor believes
that one document fits all and fills in the blanks of a specimen document.
Further, many of these specimen trust agreements are ineffective because they
are based on IRS prototype documents that are overly rigid and don't provide
donors with the flexibility to create a legitimate planning tool that meets
their unique needs. 24
In Ltr.
Rul. 200218008 , lack of communication among all the parties led to an
erroneously drafted trust document that should have been a NIMCRUT but was
drafted as a standard CRUT. The error occurred when the planned giving officer
of the charity
provided the attorney with a specimen document of a CRUT after the clients had
told their financial planner that they wanted a NIMCRUT rather than a CRUT.
Charitable
gifts are complex, and the laws governing charitable giving as well as property
law vary from state to state. Specimen documents do not take into account any
nuances in state law. For this reason, the practice of providing specimen
documents to planners has caused enough litigation to stop some insurance
companies from supplying these documents.
Planners
could seriously harm their professional reputations when they recommend
aggressive planning techniques that are later condemned by the IRS or the
courts. One of the most recently promoted aggressive charitable planning
arrangements was charitable reverse split-dollar. Under this strategy, the
donor purchased a policy and had the death benefit split between the charity and the
donor's family. However, the donor claimed a charitable deduction for the
entire premium, knowing that the donor's family would personally benefit from
this transaction. In 1999, charitable reverse split-dollar was ended by
Congress, 25 and the IRS imposed
some severe penalties in Notice
99- 36 . 26
Some life insurance
companies refused to accept or underwrite business from their agents if this
concept was behind the life insurance sale. Other companies accepted the
insurance
premiums without passing judgment on how that business came to the insurer or
how the agents advised their clients regarding tax deductibility.
Even though
Congress has enacted legislation stopping this technique, some promoters are
still using this concept. The latest version of the technique uses a CRT that
owns life
insurance
under the theory that the donor-income beneficiary is an "employee"
of the CRT. The trust is employing the donor- income beneficiary and, under this
employment theory, the charitable plan is said by promoters to fall outside the
legislation prohibiting charitable reverse split-dollar. 27 However, this plan
may raise self- dealing issues that will be sure to capture the IRS' attention.
Another
charitable scam is the "lease-purchase" of insurable interests. A charity is
approached about the purchase of life insurance inside the charity's life insurance trust,
but with a twist. The donor agrees to allow the charity to purchase a $200,000 insurance policy
on his life.
The goal is to obtain 1,000 insureds within 30 days and create a $200 million
trust. The kicker is that the insureds are guaranteed that they will never make
a cash gift or premium payment to the charity's trust. All premiums are paid by a
"good fairy" third party. When the trust reaches its goal, the good
fairy determines the discounted value of the trust and pays the charity approximately
$2,000 per insured (say $2 million in total). As the insureds die, all the insurance
proceeds are paid to the third party.
What is
really happening, of course, is that the third party-good fairy is using the charity to create
an insurable interest on 1,000 people's lives—where there was no insurable interest.
Entering into an arrangement that benefits a third party could cost the charity its
tax-exempt status because the charity is greatly aiding in the private
inurement of the third party.
From the
third party's perspective, look at the Better Business Bureau's website,
www.bbb.org/library/giftingclub, which cautions the public about "gifting
clubs" that are a third party's pyramid scheme. To join the gifting club,
individuals are asked to make a contribution to the top ranking members of the
club. Each person is then encouraged to bring in other members to advance
himself up the pyramid. Pyramid schemes frequently pay off only for those who
create the scheme, leaving many "investors" with nothing.
The above
discussion demonstrates the pitfalls that planners want to avoid as they work
to help clients in charitable planning. Clients need complete disclosure of the
advantages and disadvantages of the plan being proposed. Well-informed clients
tend to appreciate the extra effort. Take the extra time and make sure the
client's charitable plan is proposed with the client's best interests first.
These assets
need extra special handling:
These assets should
generally be avoided in charitable gift planning:
Martin v.
Section 170(a)(3) ; Rev.
Rul. 69-63, 1969-1 CB 63 .
Reg. 1.170A-4(b)(3)(i) Reg. 1.170A-4(b)(3)(i) .
See S. 1924 and H.R. 7.
Bartels' Trust,
85
AFTR 2d 2000-1352 , 209 F3d 147 , 2000-1 USTC ¶50363 .
In re Estate of
Rowe, 274 App Div 2d 87 , 712 NYS2d 662 , 2000 NY Slip Op 7374, 2000 WL 1131974 .
Crummey,
22
AFTR 2d 6023 , 397 F2d 82 , 68-2 USTC ¶12541 .
Reg. 25.2503-3 Reg. 25.2503-3 .
Statement from the National Committee on Planned
Giving and the Board of Directors of the American Council on Gift Annuities
(11/2/01), in opposition to the practice of charitable organizations paying
sales commissions to for-profit planners in connection with the sale of
charitable gift annuities.
Ltr. Rul. 199822041 .
Also see Ltr. Rul. 199804036 , in which the
grantors filed a malpractice action against the drafting attorney for the same
error as found in Ltr. Rul. 199822041 , and Ltr. Rul. 199833008 , in which the attorney
inadvertently failed to include a provision allocating realized post-
contribution gain to income.
Ltr. Rul. 8041100 ; Section
664 ; Reg.
1.664- 1(a)(3) .
Ltr. Rul. 199818027 and
Ltr.
Rul. 200002029 .
Estate of
Starkey, 83
AFTR 2d 99-2572 , 58 F Supp 2d 939 .
See, e.g., Committee
on Professional Ethics and Conduct of the Iowa State Bar Association v. Baker,
492 NW2d 695 .
The Florida Bar
v. Brumbaugh, 355 So 2d 1186 (the
selection and completion of preprinted legal documents is also the practice of
law).
Rev. Ruls. 72-395, 1972-2 CB 340 ; 80-123,
1980-1 CB 205 ; 82-128,
1982-2 CB 71 ; 82-165,
1982-2 CB 117 ; 88-81,
1988-2 CB 127 ; 92-57,
1992-2 CB 123 ; Rev.
Procs. 89-20, 1989-1 CB 841 ; 89-21,
1989-1 CB 842 ; 90-30,
1990-1 CB 534 ; 90-31,
1990-1 CB 539 ; 90-32,
1990-1 CB 546 ; and 99-1,
1999-1 CB 6 .
H.R. 1180, the Tax Relief Extension Act of 1999.
1999-1 CB 1284.
Section 170(f)(10) ; Notice
99- 36, 1999-1 CB 1284 .
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