In its latest Estate of Turner opinion, the Tax Court decided whether a pecuniary formula marital deduction clause could shield the inclusion of family limited partnership assets in the decedent's estate

In Turner the Tax Court determined that section 2036 applied to the decedent’s transfers of assets to his family limited partnership but that the insurance premiums he paid indirectly to his insurance trust qualified for the annual exclusion

The Ninth Circuit recently reversed the district court’s summary judgment in favor of the government in Linton on the issues of indirect gift and the applicability of the step transaction doctrine. The circuit court’s analysis focused on the taxpayers’ donative intent. With that emphasis,...

This article discusses the recent Tax Court decision in Pierre and the effect for gift tax purposes of an entity’s classification made under the check-the-box regulations. The court was split on what those regulations mean when they state that an entity is to be disregarded ‘‘for federal...

The article reviews the history of the tax treatment of charitable split interest gifts, explains the inequities that Congress both cured and generated in its 1969 reforms, and proposes solutions that are consistent with the goals of the 1969 legislation. The article discusses variations in the...

Jorgensen provides a common FLP story with a familiar conclusion. Under section 2036, the estate did not receive those coveted FLP discounts and paid taxes on the full value of the assets transferred to their FLPs. The court presents a careful, logical, and well-reasoned decision that should...

Although section 529, under which tax preferred college savings accounts may be established, was enacted to alleviate the large financial burden of paying for a taxpayer's family members' higher education, it has provided taxpayers with the potential for additional income, gift, and estate tax...