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

BVLaw
Court Case Digests
May 18, 2017
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
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

Estate of Powell v. Commissioner

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 ...

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

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 ...