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Providing capital to entities or individuals that go bust — tax implications

Written by Antar P. Jones, Esq., LL.M.

Published in complinet.com on March 25th 2011

Over the past several years and until now, much has been discussed concerning the tax exposure to borrowers who are forgiven of debt. Understandably, much of the discourse concerning this matter has involved the forgiveness of debts related to the real estate market as a result of the bursting of the housing bubble and the advent of the credit default swap crisis. Generally, when the debt of a taxpayer is canceled, the amount of the cancelled debt may be considered income for income tax purposes, unless an exception provided by statute applies. The rules concerning the cancellation of indebtedness are complex and evolving. Less has been discussed concerning the tax consequences to the providers of capital to individuals or entities where such investments become worthless or partially worthless.

In many instances, but not all, investors may take certain deductions when their investments go bad. The Internal Revenue Code (IRC) and the regulations under them provide for many categories of investors whose investments have gone south: (1) sellers who reacquire real property in partial or full satisfaction of indebtedness that arose from the sale; (2) those who receive amounts on the retirement or sale or exchange of debt instruments; (3) those who sustain losses during a taxable year who are not compensated for by insurance; (4) those whose securities become worthless during a taxable year; and (5) those whose debt becomes worthless (or, in the case of corporations, partially worthless) during the taxable year.

The rules regarding these categories of taxpayers are complex. Accordingly, taxpayers who believe that they may be included in at least one of the above categories at some point in time, including up to seven years ago, should speak with their firm’s accounting professional.

This article will explore some of the basic issues concerning the tax consequences of those whose debt becomes worthless or partially worthless during the taxable year, as the rules governing those taxpayers tend to be more favorable than the rules governing the other categories of taxpayers. Individuals and entities who take a deduction concerning worthless or partially worthless debts take a “bad debt” deduction pursuant to Section 166 of the IRC.

It should be noted, however, that the favorability of the tax treatment of the above categories of taxpayers tends to coincide with the degree of financial injury endured. Thus, to the extent that a taxpayer may choose the category in which to be included, the taxpayer should balance its potential tax treatment with other considerations, such as the mitigation of the loss of its investment.


To qualify for a bad-debt deduction, the bad debt must first be a bona fide debt; that is, a debt which arises out of a debtor- creditor relationship based upon a valid and enforceable obligation to pay a fixed or determinable sum of money. Also, the debt must not be evidenced by a security. Specifically, the debt cannot be a bond, debenture, note, certificate, or other evidence of indebtedness, issued by a corporation or by a governmental or political subdivision thereof, with interest coupons or in registered form. The debt must not be defined by the IRC as a “loss.” Losses generally cannot be deducted by individuals unless the losses were incurred in a trade or business, or were incurred in a transaction entered into for profit. In contrast, individuals may only take a bad-debt deduction if the debt is a non-business debt. Also, the debt must not be a retired debt instrument as, subject to narrow exceptions, those instruments are treated by another IRC provision.

It should be noted that typical bad debts are loans to clients and suppliers, certain debts of political parties, certain debts of insolvent partners, certain business loan guarantees and certain sales of mortgaged properties. However, loans to corporations that are actually capital contributions are not bad debts.


Corporate taxpayers may take an ordinary deduction for any business bad debt that becomes worthless during the taxable year, and for any business bad debt that becomes partially worthless during the taxable year, but only to the extent that it’s worthless.

In determining whether a debt is worthless in whole or in part, the relevant district director at the Internal Revenue Service (IRS) will consider all pertinent evidence, including the value of the collateral, if any, securing the debt and the financial condition of the debtor. Legal action is not required to prove worthlessness. Where the circumstances indicate that a debt is worthless, and uncollectible and legal action would not result in satisfaction of execution on a judgment, a showing of these facts will suffice as evidence of a worthless debt. However, the taxpayer must prove that worthlessness occurred in the year in which the deduction was claimed. Thus, it appears that the taxpayer must prove that the debt had value the year before.

If a debt is recoverable only in part, the district director of the IRS may allow a corporate taxpayer take a deduction in an amount that has become worthless to the extent the debt has been “charged off” during the taxable year. Charging off a debt essentially means that the taxpayer has evidenced that the debt was uncollectible on its books. Also note that the statute and its regulations have provided the district director with broad latitude to disallow deductions due to partially worthless bad debt.

Non-corporate taxpayers may take a short-term capital loss deduction for a non-business business debt that became worthless within the taxable year. A “non-business” debt is a debt other than a debt created or acquired in connection with a trade or business of the taxpayer or a debt the loss from worthlessness of which is incurred in the taxpayer’s trade or business. Also, worthless debts arising from unpaid wages, salaries, fees, rents and similar items of taxable income shall not be treated as bad debts, unless the income such items represent has been included in the tax return of income for the year for which the deduction as a bad debt has been claimed, or for a prior year.


Generally, the basis for determining the amount of the bad debt is the cost of the debt. In other words, to determine the amount of a bad debt deduction, a taxpayer will first determine the cost of the debt. The cost of the debt may in certain circumstances be different than the face amount of the obligation. In addition, one should be mindful that the Regulations have provided for specific situations concerning a debt’s basis. For example, in computing taxable income, if a taxpayer values his notes or accounts receivable at their fair market value when received, the amount deductible shall be limited to that fair market value. Also, with respect to bankruptcy claims, only the difference between the  amount  received  in distribution of the assets of the bankrupt and the amount of the claim may be deducted as a bad debt. Finally, with respect to claims against a decedent’s estate, the excess of the amount of the claim over the amount received by a creditor of a decedent in distribution of the assets of the decedent’s estate may be considered a worthless debt.


If a taxpayer did not deduct a bad-debt deduction on its original return for the year it became worthless, the taxpayer can file a claim for a credit or refund. A taxpayer may take a bad-debt deduction the later of seven years from the date the original return was due (not including extensions) or two years from the date the taxpayer paid the tax for totally worthless debts. This is a remarkable statutory allowance because generally, the limitations period for filing a claim is three years. If the claim was for a partly worthless bad debt, the taxpayer may file the claim by the later of three years from the date the taxpayer filed the original return, or two years from the date the taxpayer paid the tax.


A taxpayer filing an income tax return for the first taxable year which the taxpayer is entitled to a bad-debt deduction may in theory select one of two methods in taking bad debts into account: (1) as a deduction in respect of debts which become worthless in whole or in part; or (2) as a deduction for a reasonable addition to a reserve for bad debts. However, there is some authority that the second method is reserved only for certain financial institutions that have previously used the reserve method. Once a taxpayer has selected one of the two methods, the taxpayer should continue to use that method for all subsequent taxable years unless the IRS grants permission to use the other method. In any event, a taxpayer should provide a statement of facts with its tax return that substantiates any bad debt. The forms used to file a claim are the following:

  • Form 1040X for sole proprietors or farmers;
  • Form 1120X for corporations;
  • Form 1102S for S corporations (check box H(4));
  • Form 1065 for partnerships (check box G(5)).


  • Maintain a close, working relationship with your company’s accounting professional, to the extent that he or she is aware of any potential transactions that may qualify for a bad-debt deduction now or in the future.
  • For loans, to the extent possible, be sure that the loan does not constitute a “security” as defined by the IRC and have an attorney state as much in the loan instrument.
  • Have an attorney consider providing in every contract with a lendee, vendee, employer, partner, and the like, the circumstances under which a bad debt may arise concerning the transaction.
  • In addition, for potentially large bad debts, have general counsel consider providing in every contract with a lendee or vendee, employer, partner and the like, terms requiring the annual review of the debtor’s financial health so that in the event there is a bad debt the year of worthlessness or partial worthlessness may be more easily ascertainable. Then, if practicable, document the financial health of the debtor annually to evidence the year of worthlessness or partial worthlessness of the bad debt.

Antar P. Jones, Esq., practices law at the Law Office of Antar P. Jones, PLLC. Jones has experience advising clients concerning complex tax planning, tax controversy and estate litigation. He has also represented common clients in federal court and administrative hearings.

The Will of James Gandolfini, Jr.

BROOKLYN, NEW YORK, NOVEMBER 08, 2013. James Gandolfini, Jr., best known for his portrayal of New Jersey mobster Tony Soprano, died suddenly at age 51 on June 19, 2013 from a heart attack. Gandolfini achieved international fame for his portrayal of the lead character in the crime drama “The Sopranos”. Upon his death, his net worth was estimated at $70 million and he left behind two children. His will, and the resulting tax implications, received a vast amount of publicity, most of it negative. This article will provide some background information about Gandolfini, summarize the bequests made by his will, analyze some of the probable tax implications, and discuss alternative estate planning techniques.

James Gandolfini was from New Jersey, where he was born and raised by parents who spoke Italian at home. His father, an Italian immigrant, worked as a bricklayer and a custodian at Paramus Catholic High School; his mother was a cafeteria “lunch lady”. James was born in 1961 in Westwood, NJ and later moved to Park Ridge, NJ, where he attended the Park Ridge High School. He then went on to graduate from Rutgers University in 1983 with a degree in Communications. He became interested in acting at the age of 25 and soon began to land roles in movies and plays, including “True Romance” — a 1993 film written by Quentin Tarantino in which he played a hitman, and “Get Shorty” with costars John Travolta, Gene Hackman and Danny DeVito. Despite his success in landing these roles, and others, he had achieved little fame and remained largely unknown until, at the age of 37, he auditioned for and won the role of Tony Soprano.

The Sopranos premiered on HBO on January 10, 1999 and ran for 86 episodes over six seasons, with the final episode airing on June 10, 2007. The series told the story of a New Jersey-based Italian crime family headed by Tony Soprano, played by James Gandolfini. Gandolfini’s portrayal won him numerous accolades, and turned the character-actor into a full-fledged star. The Sopranos television series received abundant critical praise and was wildly popular. Gandolfini was nominated for six Emmy awards for his work on the Sopranos, winning three times for Outstanding Lead Actor in a Drama Series. His work also received awards from the Golden Globes, American Film Institute, Screen Actors Guild, Television Critics Association, as well as many others. Gandolfini had remained active since the conclusion of The Sopranos, starring in the Broadway play, “God of Carnage”, and in films such as “The Taking of Pelham 123” and “Zero Dark Thirty”.

Gandolfini passed away suddenly and unexpectedly from a heart attack on June 19, 2013, at the age of fifty-one in Rome, Italy. Gandolfini was vacationing with his family and was expected to later attend the Taormina Film Festival in Sicily, where he was to receive a special award. He was survived by his wife, Deborah Lin Gandolfini, their 9-month-old daughter, Liliana, and his son, Michael, from a prior marriage that ended in divorce. He was also survived by his sisters, Leta Gandolfini and Johanna Antonacci. Most reports estimated Gandolfini’s net worth, at the time of his death, to be somewhere close to $70 million.

Soon after his death the media’s attention turned to the actor’s will, the generosity of the gifts made thereunder, and the potential taxes due from the estate. “Experts” were interviewed regarding the estate plan, which was described as a tax “disaster” by one article and by another as a $30 million mistake. Gandolfini’s own attorney, Roger S. Haber, then responded to these accusations in an interview with the New York Times defending the plan.

What can be learned from this controversy? The objective of the remainder of this article is to utilize Gandolfini’s controversial estate plan as an example illuminating the considerations to be weighed when creating such a plan. It will not reach a conclusion as to whether Gandolfini’s plan was “correct” or “incorrect”, given that the actor’s intentions are unknown to the public, the possible existence of confidential planning techniques that may have been utilized, and the uncertainty of the actor’s true net worth, any such conclusion would be largely speculative.

Gandolfini signed his will on December 19, 2012, six months prior to his death. The will is straightforward and the relevant portions are summarized below:

  • Gandolfini’s clothing and jewelry went to his son, Michael.
  • All other personal property, other than currency, went to his wife, Deborah Lin.
  • Seven named individuals, consisting of his assistant, three friends, two nieces, and his godson, received bequests of a specific dollar amount. These bequests totaled $1.6 million.
  • The residue of the estate is devised as follows:
  • 30% to Gandolfini’s sister Leta;
  • 30% to Gandolfini’s sister Johanna;
  • 20% to Gandolfini’s wife Deborah Lin; and
  • 20% to Gandolfini’s daughter Lilliana Ruth.
  • A trust previously created by Gandolfini for his son Michael is given the first option to purchase his condominium and parking spot in Greenwich Village, NY.
  • His son, Michael, and daughter, Lilliana, each receive a 50% interest in a trust that owns Gandolfini’s home in Italy.
  • The will specifically mentions that Gandolfini made “other provisions” for his wife, Deborah Lin, and his son, Michael, presumed to refer to provisions made outside the will.

Other factors relevant to the estate plan, but not part of the will, are as follows:

  • Court documents value the property covered by the will to be between $1 million and $10 million.
  • It is speculated that the existence of other assets not covered by the will may explain reports that his estate was worth $70 million when he died.
  • Gandolfini’s son, Michael, had a non-testamentary life insurance trust put aside for him until he turns 21 (mentioned above). According to an affidavit attached to the will, the trust was part of a 2002 divorce settlement with ex-wife Marcela Wudarski and owns a life insurance policy worth approximately $7 million.

The primary criticism leveled against Gandolfini’s will was that because of the dispositions made, his estate would be subjected to unnecessary and excessive estate taxes. One article asserted that 80% of his estate was unprotected against estate taxes with rates as high as 55 % when considering both Federal and State taxes. This was based on the fact that the will did not take advantage of the unlimited spousal deduction, which allows a surviving spouse to inherit an unlimited amount from their deceased spouse exempt from taxes. Gandolfini’s will left 80% of his residuary estate to people other than his spouse. The taxes imposed on these dispositions are the basis for this line of criticism. The critics seem to ignore, however, several important considerations that may nullify their comments.

First, Gandolfini may have not wanted to leave his surviving wife his entire estate. The critics seem to suggest that taxes are by necessity the primary motivation when drafting a will. However, Gandolfini may have had other motivations. Secondly, the will specifically states that Gandolfini made “other provisions” for his wife and son. This may allude to substantial lifetime transfers of Gandolfini’s assets to trusts, not made public. Finally, the criticism assumes that Gandolfini’s residuary estate was large enough that substantial taxes would be imposed. As Gandolfini’s own lawyer said, “everyone is focusing on some number that someone made up and the will as if it were the entire estate plan”. If, during his lifetime, Gandolfini transferred assets to other individuals or through trusts, he may have diminished the size of his probate estate considerably. These transfers may have utilized techniques that result in tax-advantaged valuation discounts, further reducing the tax burden. Without knowing this critical information, the criticism may be entirely unwarranted.

Another line of criticism directed at the will is much more straightforward and hard to disagree with. Unlike most celebrities, who usually keep these sorts of matters private, Gandolfini’s will became a matter of public record when it was filed in Manhattan’s Surrogate Court. Gandolfini should have considered keeping his affairs private. He could have accomplished this by using a “pour-over will” which would simply state that his possessions be placed into a trust, the particulars of which are private. It would have kept the details of the bequests out of the purview of the public, which would have avoided all the negative publicity and critical commentary.


  • Firstly, make sure you have a properly drafted and executed will that accurately reflects your wishes.Consider having the following additional vital documents: living will, health-care proxy, durable power-of-attorney.
  • Find an attorney who is competent and appropriate for you to work with in drafting an estate plan.
  • If you desire to keep the bequests private, consider using a pour over will with a trust that is private, and which can be changed at anytime.
  • Coordinate your will’s provisions with your investments, life insurance and other financial planning to ensure that there is a smooth transition if something does happen to you.
  • Consider tax-efficient gifts and transfers, such as irrevocable life insurance trusts like the one left to Gandolfini’s son, Michael.
  • Remember that foreign property is different. Inheritance laws may be different in foreign countries and override the decisions stated in your will, so consult with local legal experts.
  • Consider treating children equally when it comes to division of assets. It may be tempting to be “fair” but disparate treatment may leave children questioning the love of the deceased parent. It may also create rivalry between the children or cause old rivalries to resurface. However, sometimes it may be reasonable to divide your assets in an attempt to even out financial disparities between descendant children.
  • Consider the ages of children carefully and whether they will be mature enough to manage the assets that you have left to them. It may be advisable to wait until they have finished college, or that it be kept in a trust long-term to protect it from creditors and predators, or that gradual distributions be made starting at a certain age, allowing the children to learn how to manage money and/or hire experts to do it for them.
  • Consider explaining to your children the reasons behind the specifics of your estate planning and clear up any misunderstandings.
  • Finally, do think about taxes, but don’t let taxes rule your decisions.

Disclaimer: The information presented in this blog post should not be construed to be formal legal advice on any subject matter. Always seek the advice of a qualified lawyer with any questions you may have regarding a legal situation. Reproduction, distribution, republication, and/or retransmission of text contained within the AntarLaw.com Website are prohibited unless the prior written permission of Antar P. Jones, Attorney at Law has been obtained.

A Peaceful Body: Planning for the Disposition of One’s Remains Upon Death

BROOKLYN, NEW YORK, APRIL 21, 2013.  The question of what will happen to one’s remains after death is a difficult one to contemplate. No one likes to think of death, especially their own or that of a loved one. However, with an increase in couples choosing various arrangements over traditional marriage, post-mortem planning has become more challenging.  Additionally, as some publicized court cases have shown, conflicts and disputes between estranged family members can easily develop.

Of note is the case involving the late baseball legend, Ted Williams. After his death from cardiac arrest in 2002, Williams’ children from a second marriage quickly had their father’s body frozen by cryostasis. They claimed that doing so was in accordance with Williams’ wishes and that he had memorialized his desires on the back of a napkin. Williams’ oldest daughter went to court to dispute the validity of the ‘document.’ She claimed that her siblings had had their father frozen with intentions of extracting and selling his DNA, and that her desire was simply to honor her father’s wishes as stated in his 1996 will. Indeed many of Williams’ friends and family claimed that they distinctly remembered him saying that he wanted to be cremated and have his ashes spread across the Florida Keys in accordance with his will. After many months in court, the daughter agreed to drop the lawsuit due to financial difficulties. Williams’ body remains frozen at Alcor Life Extension Foundation in Scottsdale, Arizona.

Another case that made the headlines involved a dispute between two parents over where their son would be buried. Staff Sergeant Jason Hendrix’ parents had divorced when he was a child, and his father was awarded custody. Hendrix had grown up in California with his mother, but moved to Oklahoma to live with his father. Sadly, Sgt. Hendrix was killed in battle during the Iraq war. He was unmarried, had no children and left no will. In accordance with Pentagon policy—which states that custody is granted to the eldest next of kin, custody of his remains went to his father, who was three years the mother’s senior. His mother argued that before his death, Hendrix had expressed a desire to be buried in California. Citing the fact that Hendrix had possessed an Oklahoma driver’s license, that Oklahoma was his state of legal residence and that there was evidence that he had planned to live in Oklahoma upon his return from the Army, the court ruled in favor of his father stating that Hendrix was to remain buried in Oklahoma, where his father had buried him.

These cases underscore the need for an individual to prepare a document that will aid in avoiding such conflicts. In the State of New York, the Appointment of Agent to Control Disposition of Remains Form is a document that an individual can use to appoint someone who will be responsible for the final disposition of his/her bodily remains after death. The document allows the designated individual, or “agent”, to have priority with regards to the disposition of one’s  remains regardless of whether they are next of kin or not. This is especially important for individuals who are single, or members of nontraditional families.

According to New York Public Health Law section 4201, there is a designated hierarchy of individuals who have the right to control the disposition of a decedent’s remains. They are as follows:

(i) the person designated in a written instrument;

(ii) the decedent’s surviving spouse;

(ii-a) the decedent’s surviving domestic partner;

(iii) any of the decedent’s surviving children eighteen years of age or older;

(iv) either of the decedent’s surviving parents;

(v) any of the decedent’s surviving siblings eighteen years of age or Article 17-a of the Surrogate’s Court Procedure Act (SCPA) or Article 81 of the Mental Hygiene Law;

(vii) any person eighteen years of age or older who would be entitled to share in the estate of the decedent as specified in section 4-1.1 of the Estates, Powers and Trusts Law:

a) Grandchildren;

b) Great-grandchildren;

c) Nieces and nephews;

d) Grand-nieces and grand-nephews;

e) Grandparents;

f) Aunts and uncles;

g) First cousins;

h) Great-grandchildren of grandparents; and

i) Second cousins—with the person closest in relationship having the highest priority;

(viii) a duly appointed fiduciary of the estate of the decedent;

(ix) a close  friend or relative who is reasonably familiar with the decedent’s wishes, including the decedent’s religious or moral  beliefs, when  no  one  higher  on this list is reasonably available, willing, or competent to act,     provided that  such  person  has  executed  a  written statement pursuant to subdivision seven of this section; or

(x) a chief  fiscal  officer  of  a county or a public administrator appointed pursuant to article twelve  or  thirteen  of  the  SCPA,  or  any  other  person  acting  on behalf of the decedent, provided that such person has           executed  a  written  statement pursuant to subdivision seven of this section.

Public Health Law section 4201 provides for individuals to appoint an agent through an Appointment of Agent to Control Disposition of Remains Form. The form provides a section where one may appoint an agent. Also one may set forth special directions limiting the agent’s powers or instructions to be followed in the disposition of remains. The form allows an individual to appoint a successor agent and a successor to the successor. In order for the form to be valid, it must be signed by the agent and witnessed by two individuals, who must also sign it.

The Appointment of Agent to Control Disposition of Remains Form may provide clarity and peace to families with complex emotional dynamics. In addition, preparing this form may help estates and family members avoid undertaking costly legal disputes for a small fraction of their cost.


Disclaimer: The information presented in this blog post should not be construed to be formal legal advice on any subject matter. Always seek the advice of a qualified lawyer with any questions you may have regarding a legal situation. Reproduction, distribution, republication, and/or retransmission of text contained within the AntarLaw.com Website are prohibited unless the prior written permission of Antar P. Jones, Attorney at Law has been obtained.

Hizzoner’s Will

BROOKLYN, NEW YORK, MARCH 15, 2013.  Sadly, we shall not find the former mayor of New York City eating lunch at Aquagrill, a favorite Soho eatery. The will of former Mayor Ed Koch was filed this past Monday in Surrogate’s Court in Manhattan. Mr. Koch, who died on Feb. 1 at the age of 88 from congenital heart failure, served as New York City Mayor between 1978 and 1989. His estate is said to be valued between $10 million and $11 million. Mr. Koch’s post-mayoral earnings came from his law practice, books, speaking engagements, published commentaries and television commercials.

The former mayor left sizeable amounts to both family and friends, as well as to a charity that he cared for dearly. Specifically, he left $100,000 to Ms. Mary Garrigan, his longtime secretary, whom he first hired to work in his Washington, D.C. congressional office in 1975. He also left $100,000 to the LaGuardia and Wagner Educational Fund at the City University of New York, which will be used to create a program for public and government service.

However, the majority of Mr. Koch’s estate was left to his family. He gave $50,000 each to his sister-in-law, his nephew and his niece. He also left $500,000 jointly to his sister and brother-in-law. The remainder of Mr. Koch’s estate, after funeral expenses and lawyers’ fees, will be shared equally between his sister’s three sons. It is said that the former Mayor’s estate shall be subject to $1.45 million in federal estate tax and $1.1 million in New York State estate tax, presuming that the estate is valued at $10.5 million.

Hizzoner could have made certain estate planning choices to protect his estate from creditors, to keep his financial matters private and to minimize his estate from exposure to estate tax. For example, if Mr. Koch had set up lifetime trusts to his nephews, such trusts could have protected them from creditors or divorcing spouses, if any. In addition, creating such trusts could have had the benefit to some degree of secrecy, as trusts are not public documents like wills entered for probate.

Mr. Koch could have minimized his estate from federal and New York State estate tax exposure by making annual gifts to his beneficiaries, as well. The federal tax code currently provides that, generally, grantors who make gifts over $14,000 to individuals during a given year must pay a gift tax. Thus, Mr. Koch could have made an annual $14,000 gift to each of the beneficiaries named in his will and would have not incurred a gift tax. Although there is currently no New York State gift tax, making such gifts would have also minimized his taxable estate for New York State estate tax purposes. Finally, the federal tax code provides that the Mayor could have made up to $5.25 million in lifetime gifts without having to pay a gift tax. Thus, Mr. Koch could have made large deathbed gifts free of federal estate tax. Said gifts would have also minimized his taxable estate for New York State estate tax purposes.

Nevertheless, in making an estate plan, one should balance tax considerations with one’s understanding of family dynamics, the cost of administering an estate and one’s long term goals and priorities. Thus, each estate plan should be created for each individual. Choosing an attorney who understands this is challenging, yet critical. However, doing so may leave loved ones happier, wealthier and with less stress.


Disclaimer: The information presented in this blog post should not be construed to be formal legal advice on any subject matter. Always seek the advice of a qualified lawyer with any questions you may have regarding a legal situation. Reproduction, distribution, republication, and/or retransmission of text contained within the AntarLaw.com Website are prohibited unless the prior written permission of Antar P. Jones, Attorney at Law has been obtained.

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