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Under the terms of the guarantee, the Service reasoned, the taxpayer's estate would become liable for the loan guarantee; any property that could be used to satisfy that guarantee could not qualify for the marital deduction, since such property was at least potentially "encumbered" with the guarantee.

Since many parents guarantee their children's loans, this ruling has caused great concern. In Letter Ruling 9409018, the IRS reversed its 1990 ruling and stated that the marital deduction should not be reduced by the entire unpaid balance of the guaranteed loans, unless at the time of the taxpayer's death it appeared that a default was imminent, performance under the guarantee was likely and any subrogation rights were worthless.

If it was determined that the marital deduction would have to be reduced as a result of default being imminent, the estate should be able to take a deduction for payment of the guaranteed obligation. In Letter Ruling (TAM) 9321004, the question arose as to whether a decedent's estate could claim a deduction under Sec.

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Sanjum Sethi, a cardiologist at Columbia University Medical Center. Baytown is a city in Harris County, Texas situated east of State Highway 146 and south of Interstate 10. Travel twenty two miles west you will find yourself in Houston; travel south instead toward the Gulf of Mexico and you arrive in Galveston. Baytown located at the mouth of the San Jacinto River had a population just under 72,000 in 2010. Few tunes are prepared in advance.

The songlist evolves as people sit in, so the house band must have a huge list of jazz tunes in its repertoire. It is a spontaneous and very dynamic evening of creating and improvising. Sen. Bernie Sanders (I Vt. ), who is seeking the Democratic nomination for president, has proposed the College for All Act, for instance, a cost sharing program that would send 47 billion a year to states who agree to increase their higher education funding.

Yet there has been little mention of the more than 45 million people already burdened with student loans, which makes Warren's debt cancellation plan a standout, liberal policy analysts say. "Warren is recognizing that we will not be able to make tuition free without addressing past harm done by student debt," said Sara Goldrick Rab, a professor of higher education policy and sociology at Temple University.

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