A client won a significant victory before the Pennsylvania Board of Finance and Revenue in Jeffrey and Marsha Perelman, BF&R Dkt. No. 181005. Our firm represented the client in the matter.
The client exchanged several million dollars of artwork in a transaction that qualified for tax-free treatment under Section 1031 of the Internal Revenue Code, but the Pennsylvania Department of Revenue argued that the exchange was taxable for Pennsylvania income tax purposes. The Board of Finance and Revenue ruled for the client, holding that the state’s argument was contrary to its own guidance and that the client was entitled to tax-free treatment based on its method of accounting.