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Federal district court finds promoter of “Aegis” system of “trusts” guilty of conspiracy to defraud and aiding the filing of a false tax return

Proskauer Rose LLP
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USA
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April 16 2010

The defendant in Wasson was found guilty of conspiracy to defraud and of aiding in the filing of a false tax return

Federal district court finds transfer of interests in LLC to children does not qualify for the annual gift tax exclusion Fisher v. Commissioner, No. 1:08-CV-00908 (March 11, 2010)

Proskauer Rose LLP
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USA
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May 7 2010

A U.S. District Court in Indiana found the transfer of interests in a LLC to children did not qualify for the annual gift tax exclusion because the interests were considered “future” rather than “present” interests in property due to operating agreement restrictions on the children’s rights relating to the property

Step transaction doctrine applies to aggregate gifts and sales to trusts

Proskauer Rose LLP
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USA
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July 1 2010

In Pierre v. Commissioner, T.C. Memo 2010-106 (May 13, 2010), the Tax Court held that the step transaction doctrine applied to collapse the taxpayer's gifts and sales of LLC membership interests to trusts

Court limits amount that surviving spouse was entitled to claim for tax on prior transfers under 2013

Proskauer Rose LLP
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USA
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November 5 2010

This case involves credits for tax on prior transfers under IRC 2013

Court finds Tax Court erred when it apportioned entire value of a Manhattan brownstone to a decedent’s estate when decedent transferred 49 of the property to her son a few years before

Proskauer Rose LLP
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USA
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November 5 2010

In this case the higher court reversed a lower court's inclusion of the entire value of a real property in the Decedent's estate when the decedent had transferred a portion of the property to her son during her life

Decedent had no ownership interest in companies despite his involvement in the business

Proskauer Rose LLP
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USA
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July 1 2010

In Estate of Fortunato v. Commissioner, T.C. Memo 2010-105 (May 12, 2010), the Tax Court ruled that the decedent had no ownership interest in various companies despite his involvement in the operation of the companies

No charitable contribution deduction for donation of house to local fire department where value of demolition services exceeded value of property

Proskauer Rose LLP
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USA
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December 6 2010

In Theodore R. Rolfs, et ux. V. Comm’r, 135 T.C. No. 24 (1142010), the Tax Court denied a charitable contribution deduction for donation of a house to the local fire department where the value of the demolition services that the taxpayer would receive exceeded the value of the donated property

Federal Court of Claims holds that primary executor of estate was not entitled to reissuance of $10 million refund when check was previously issued to and negotiated by an ancillary executor

Proskauer Rose LLP
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USA
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April 16 2010

The Federal Court of Claims recently denied a U.S. executor’s claim for a federal tax refund when the IRS had previously issued a refund check to a non-U.S. ancillary executor

Loan interest paid by trust held non-deductible in decedent’s estate because it was unnecessary

Proskauer Rose LLP
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USA
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November 5 2010

After Decedent’s death, his trust borrowed $1.5 million from Decedent’s Foundation to pay his estate tax liabilities (aka a “Graegin” loan

8th Circuit finds limited partnership’s transfer restrictions disregarded when valuing stock for gift tax purposes - Holman v. Commissioner, 2010 WL 1331270 (April 7, 2010)

Proskauer Rose LLP
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USA
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May 7 2010

The 8th Circuit, in affirming the Tax Court, found that a limited partnership created by a couple to hold Dell stock in trust for their children could not claim that the partnership's transfer restrictions constituted a bona fide business arrangement

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