According to a recap
of the recent 52nd Heckerling Institute on Estate Planning, the IRS continues to question the value of self-canceling installment notes (SCINs), but “taxpayers may still see success concerning valuation of the notes.” It notes the settlement in Estate of Johnson v. Commissioner,
T.C. Docket No. 11708-16 (filed May 16, 2016), where the IRS had questioned the value of a SCIN granted in exchange for shares in a closely held entity. Apparently, the settlement favored the estate. A SCIN is a debt obligation, which, in the event of the death of the seller/creditor, will be extinguished with the remaining note balance automatically canceled. Estate planners use SCINs when transferring a family business from one generation to another.
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