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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.

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It was an accidental discovery. I was surfing on the net for some blog site and landed on Hub pages, specifically, Prem Singh's hub on 'online money making'. As a most unusual year comes to an end, finance minister Nirmala Sitharaman is confident that the government's interventions to revive the economy are working and says reforms will continue with a strong focus on infrastructure.

Excerpts from a conversation with Sidhartha, Surojit Gupta and Rajeev Deshpande:There have been some positive numbers over the last two days, and last week you spoke of near zero growth this year. Do you expect a strong bounce back in the second half and what are the reasons?A steadily positive message is coming, whether it's increased GST collections, car and two wheeler figures, exports, FDI inflows, forex reserves, today's PMI numbers, or the rural economy sustaining its positive growth.

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