Today’s Associated Press (Lone Accountant Takes on IRS and Wins) has an interesting story about C. D. Ulrich, the Minnesota accountant behind this month’s big victory by policyholders of over thirty big mutual insurance companies which "demutualized" and became publicly traded corporations in the 1990s in Fisher v. United States, No. 04-1726T (Ct. Fed. Cl. 8/6/08). As Joe Kristan explains:
In a decision that will prompt thousands of tax refund claims, the Court of Federal Claims has ruled against the longstanding IRS position that assigns zero basis to stock received in insurance company demutualizations. The court ruled that basis should be allocated to the stock of the policy up to the amount of the sales price of the stock uner the "open transaction" doctrine.
See also WebCPA, TaxAlmanac.
3 responses to “AP: The Accountant Behind the Policyholders’ Win in “Demutualization” Case”
BIG MEDIA AND DEMUTUALIZATION
The Associated Press has run a profile on Charles Ulrich, the Minnesota CPA behind the recent IRS defeat on demutualization….
BIG MEDIA AND DEMUTUALIZATION
The Associated Press has run a profile on Charles Ulrich, the Minnesota CPA behind the recent IRS defeat on demutualization….
BIG MEDIA AND DEMUTUALIZATION
The Associated Press has run a profile on Charles Ulrich, the Minnesota CPA behind the recent IRS defeat on demutualization….
BIG MEDIA AND DEMUTUALIZATION
The Associated Press has run a profile on Charles Ulrich, the Minnesota CPA behind the recent IRS defeat on demutualization….
BIG MEDIA AND DEMUTUALIZATION
The Associated Press has run a profile on Charles Ulrich, the Minnesota CPA behind the recent IRS defeat on demutualization….
BIG MEDIA AND DEMUTUALIZATION
The Associated Press has run a profile on Charles Ulrich, the Minnesota CPA behind the recent IRS defeat on demutualization….
BIG MEDIA AND DEMUTUALIZATION
The Associated Press has run a profile on Charles Ulrich, the Minnesota CPA behind the recent IRS defeat on demutualization….
BIG MEDIA AND DEMUTUALIZATION
The Associated Press has run a profile on Charles Ulrich, the Minnesota CPA behind the recent IRS defeat on demutualization….
BIG MEDIA AND DEMUTUALIZATION
The Associated Press has run a profile on Charles Ulrich, the Minnesota CPA behind the recent IRS defeat on demutualization….