The IRS concluded that Y's primary reason for the sale was an unforeseen
Rising costs hit profit margins in a huge way, and if your project didn't start out with a big enough profit margin before the "surprise factor" of unforeseen
cost increases, then you don't have enough profit in the deal to make any money.
If this could not be achieved, the Fed would not be able to play its role as a responsible central bank if any unforeseen
risk arose, as monetary policy would not be effective.
121-3(e) allows a reduced exclusion if the primary reason for the sale or exchange is the occurrence of unforeseen
circumstances, defined as an event that the taxpayer could not reasonably have anticipated before purchasing and occupying a residence.
Various questions need to be asked: How will unforeseen
events impact working capital requirements?
Under the temporary (and proposed) regulations, a sale or exchange is due to unforeseen
circumstances if the primary reason for the sale or exchange is the occurrence of an event that the taxpayer does not anticipate before purchasing and occupying the residence.
The important point here is that this owner used the strength of his firm's cash flow to attract long term financing as a hedge against an unforeseen
If the indebtedness is incurred because of an unforeseen
substantial loss of income or unforeseen
substantial increase in the taxpayer's financial obligations, the deduction will be allowed under this rule, even though the loan is used to pay premiums on the contract.
While travel insurance may cover such unforeseen
emergencies, experts warn consumers to be on guard.
allows excuse from contractual obligations when performance becomes "commercially impractical" or extremely and unreasonably difficult to perform due to an unforeseen
Occurrence: A True Story is tale of a man who became lost in the alluring and all-consuming bustle of the fast life, and then became afflicted with a medically catastrophic event.
Under the latter provision, taxpayers may still qualify for a reduced maximum exclusion if the sale or exchange was due to a change in place of employment, health or unforeseen
circumstances; the regulations provide safe harbors to qualify.
121-3T(b) states that, for a taxpayer to claim a reduced maximum exclusion under section 121 (c), the sale or exchange of the taxpayer's residence must be due to a change in place of employment or in health or due to unforeseen
circumstances, which depend on the facts and circumstances.