Tax Court’s Novel Theory Aims to Prevent ‘Double Inclusion’

Business Valuation UpdateVol. 23 No. 7
BVLaw Case Update
July 2017

Access the Full Article

This article is available with a subscription to any of these products:
Already a subscriber?  Login
This article is also available for purchase. (530 words)   Add to Cart >>
Need help? Contact us:
1-503-479-8200 ext 2 or sales@bvresources.com
estate and gift taxation
family limited partnership (FLP), estate tax, gift tax, trustee, estate planning, section 2036, annuity
Estate of Powell v. Commissioner
2017 U.S. Tax Ct. LEXIS 19
May 18, 2017
US
Federal Court
Federal
United States Tax Court
N/A (estate/petitioner); N/A (IRS/respondent)
Halpern

Summary

Tax Court finds assets transferred into family limited partnership on behalf of incapacitated decedent shortly before death are includible in gross estate under IRC section 2036(a)(2); to avoid “double inclusion,” court states new rule limiting includible ...

See Also

Tax Court’s Novel Theory Aims to Prevent ‘Double Inclusion’

Court Case Digests
May 18, 2017

Tax Court finds assets transferred into family limited partnership on behalf of incapacitated decedent shortly before death are includible in gross estate under IRC section 2036(a)(2); to avoid “double inclusion,” court states new rule limiting includible ...