In their article entitled “Attorney Fees and Private Annuity Rules” TAX NOTES, January 22, 2007, http://papers.ssrn.com/sol3/papers.cfm?abstract_id=958185 Messrs. Raby and Raby embark on an intriguing discussion on this topic and argue that deferred attorney fees fit under the private annuity rules. On page 311, item 4. they state that, “We believe…
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