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Louis Vlahos

Louis Vlahos practices tax law and has extensive experience in corporate, individual and partnership income taxation, and in estate and gift taxation, including tax planning, ruling requests and tax controversy.

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Encourage But Verify

“It is more blessed to give than to receive.”[i]

Undoubtedly, you’re familiar with the foregoing proverb that seeks to encourage “charitable behavior” among the members of society, and to dissuade them from pursuing only their innately selfish proclivities.[ii]

The Code recognizes the conflict that an individual taxpayer may experience in the course of deciding whether to make a charitable contribution of a property, or to retain such property (or the proceeds from its sale) for the individual’s own use.

Continue Reading “For Want of a Nail” – A Poor Reason to Lose a Charitable Contribution Deduction

State of the Economy?

According to statistics released by the Administrative Office of the U.S. Courts for the twelve-month period ending Dec. 31, 2025, bankruptcy filings by businesses rose 7.1 percent and non-business filings increased by 11.2 percent. Total filings have increased each quarter since June 2022, though they remain lower than historical highs.[i]

Do these statistics somehow reflect the state of the U.S. economy, generally?

Continue Reading No Matter How Bad it Gets . . . Pay Your Withholding Taxes?

Acquiring a NYC Residence

According to a recent report, Manhattan boasted the most expensive residential real estate market in the country last year. “Manhattan residents spend nearly five times the national average for housing.”[i]

That shouldn’t surprise anyone, considering what has been, at least up to this point, Manhattan’s status as the nation’s financial capital, its unmatched cultural offerings, its urban amenities and lifestyle, the high salaries that enable buyers to bid up prices, and the limited supply of housing.

Continue Reading Purchasing Residential Property in NYC: Coordinating State Tax and Beneficial Ownership Rules

New York’s Assault on Real Property

Last month, New York’s governor announced that the State’s FY 2027 budget will include the enactment of an annual surcharge on second homes[i] in New York City that are valued at $5 million or more.[ii]

Query how much greater the city’s deficit must be before the $5 million threshold is reduced to $4 million, or maybe less? As some of you will appreciate, once the administration of a tax has been implemented, it doesn’t require much effort to expand its coverage, especially in the hands of a spendthrift government.   

Continue Reading Tax Considerations for Individuals Targeted by New York’s Assault on Real Property Ownership

Perception of Taxes

Since I started practicing almost forty years ago, there have always been a relatively few well-to-do individuals for whom the payment of any taxes – whether personal or business – under any circumstances, seemed to be the most odious and excruciating task they were ever required to perform.

The fact they had…

Reality Check?

A few days ago, Sen. Wyden, the Ranking Member on the Senate Finance Committee, introduced a bill to tax carried interests as ordinary income on a current basis.[i] A day earlier, Sen. Van Hollen introduced a bill to reduce the federal estate tax exemption to $3.5 million and the gift tax exemption to $1.0 million.[ii]

In fact, Democrats in Congress have been introducing a number of tax bills over the last few weeks that convey a consistent theme: it’s time to tax the wealthy.[iii]

Continue Reading Tax Planning and The Political Pendulum

Taxes equal Revenue

The Administration just released its proposed budget for Fiscal Year 2027.[i] The Budget proposes to streamline IRS operations by reducing the agency’s budget to $9.8 billion – a $1.4 billion cut from current spending levels,[ii] including a reduction of its enforcement workforce by 17 percent – while utilizing improvements in technology to ensure the tax laws are fairly and efficiently administered.

Continue Reading Estate Tax Collection: An Illustration of Payment Options, Decisions, and Consequences

C’mon Already

New York has once again missed its April 1 budget deadline, in no small part because the Governor’s party, which controls both the State Senate and Assembly,[i] is once again at odds with the Governor over tax policy.

The Legislature is pushing for tax increases on businesses and on high earners, while the Governor opposes raising the personal income tax but is willing to extend the “temporary” increase in the top tax rate for corporations.[ii]

Continue Reading The “Mandated” New York S Corporation Election – Does Investment Income Include Gain from the Sale of Goodwill?

The Struggling Business

When things start to go badly in a business, its owners may feel compelled to take certain extraordinary, and usually ill-conceived, measures “to keep the doors open and the lights on.”

For instance, when faced with a reduction in positive cashflow,[i] the owner may decide to forgo the remittance of sales taxes or employment taxes properly withheld by the business,[ii] or the payment of other taxes owed by the business, and instead divert such funds toward the payment of business expenses.

It’s an old story. The owner of the business acknowledges their failure to satisfy its tax obligations, and recognizes that serious consequences may result therefrom. Still, the owner will rationalize their decision to forgo payment by convincing themselves that once the business has turned the proverbial corner, it will discharge whatever taxes may be owing at that time (plus interest and any penalties).

Continue Reading A Corporation’s Loss of Capacity and the Tax Court’s Jurisdiction

The Tax Court has previously held that a partner who contributes his own note to a partnership in exchange for a partnership interest takes no basis in the interest and their capital account is not credited for the value of the contribution. 

In the case discussed below, an entity that was disregarded for purposes of the income tax received a promissory note from its sole owner, which it then contributed to a newly formed partnership in exchange for an interest in that partnership.[i]

What followed was not intended by the parties.

Continue Reading Unforeseen Tax Consequences Arising From an Elective Change in Entity Classification