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Knappe v. U.S., 111 AFTR-2d 2013-1531 (9th Cir.)

Proskauer Rose LLP
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USA
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June 3 2013

The executor relied on the advice of his accountant that the time period for both extending the time to file an estate tax return as well as the time

TAM 201317010 (April 26, 2013)

Proskauer Rose LLP
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USA
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June 3 2013

In this TAM, Trust A and Trust B owned interests in Company X. B was a Trustee of both Trust A and Trust B. A was a shareholder in Company X and a

Estate of Liftin v. U.S., 111 AFTR-2d 2013-1426 (Ct. Fed. Cl.)

Proskauer Rose LLP
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USA
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June 3 2013

The Court of Federal Claims held that an estate was not entitled to a refund of a late-filing penalty because the estate lacked reasonable cause for

U.S. v. Blake, E.D.N.Y, No. 12-cv-02577

Proskauer Rose LLP
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USA
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June 3 2013

The U.S. District Court for the Eastern District of New York abstained from jurisdiction in a claim by the government to collect estate taxes because

June interest rates for GRATs, sales to defective grantor trusts, intra-family loans and split interest charitable trusts

Proskauer Rose LLP
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USA
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June 3 2013

The June 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.2, which is a slight decrease from April's rate

Tax Court holds that trusteebeneficiary's power to invade trust principal for her "welfare" is limited by an ascertainable standard and trust principal not includible in her estate under IRC 2041(b)(1)(a) estate of Ann R. Chancellor, et al. v. Commiss

Proskauer Rose LLP
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USA
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September 14 2011

Frequently, trust agreements ensure that the principal invasion power held by a trustee who is also a beneficiary is limited to distributions for the beneficiary's "health, education, maintenance and support"

Towbin v. Towbin, 36 Misc. 3d 1236(a) (N.Y. Sup., August 22, 2012)

Proskauer Rose LLP
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USA
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December 7 2012

A New York court ruled that a transfer to a grantor retained interest trust ("GRIT") was not a completed gift, since title on the underlying property was never formally transferred

U.S. government sues estate and donees of J. Howard Marshall II for unpaid gift taxes

Proskauer Rose LLP
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USA
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November 5 2010

The U.S. government is suing the estate and donees of J. Howard Marshall for a combined $85 million of unpaid gift and GST taxes

Estate of Nancy P. Young v. United States (D. Mass., No. 1:11-cv-11829-RWZ, 121712)

Proskauer Rose LLP
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USA
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February 12 2013

In Estate of Nancy P. Young v. United States, the District Court upheld a latefiling penalty against an estate whose accountants advised it to file

Surviving spouse is not treated as the payee of the decedent’s IRA and therefore could not take the IRA and roll it over into an IRA in her own name

Proskauer Rose LLP
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USA
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March 10 2010

In this PLR, the IRS found that the decedent's surviving spouse was not treated as the payee of the decedent's IRA, and therefore she could not take the IRA and roll it over into an IRA in her own name

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