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 ...
Activist Tax Court takes on double inclusion problem in estate and gift tax case
In an estate and gift tax case, the U.S. Tax Court recently sided with the Internal Revenue Service when the court found the value of assets transferred from the decedent to a family limited partnership was includible in the value of the decedent’s gross estate. The real surprise lay in the court's decision to propose a new way of calculating the includible amount.
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 ...
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 ...
Estate of Kite v. Commissioner
At issue in this taxpayer action was whether the transfer of family partnership interests held by the decedent's lifetime revocable trust to her children in exchange for private annuity agreements was a disguised gift subject to gift tax.