Search results

Order by most recent / most popular / relevance

Results: 11-20 of 34

Court rescinds nonqualified disclaimer and denies gift tax liability

Proskauer Rose LLP
-
USA
-
November 5 2010

In this case, a disclaimant's parents set up Qualified Personal Resident Trusts ("QPRTs") that passed to the disclaimant, Craig, and his sister after the QPRT terms expired

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

Proskauer Rose LLP
-
USA
-
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
-
USA
-
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

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
-
USA
-
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

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

Proskauer Rose LLP
-
USA
-
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

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

Proskauer Rose LLP
-
USA
-
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

Estate not entitled to discount the value of three marital trusts for claims by ESOP members against the marital trusts’ assets Estate of Foster v. Comm’r, T.C. Memo 2011-95 (4282011)

Proskauer Rose LLP
-
USA
-
July 5 2011

In Foster, the Tax Court considered the following: (1) whether an estate was entitled to discount the value of assets in three marital trusts due to the potential for litigation; and (2) whether assets in the marital trusts could be discounted for lack of control over and lack of marketability of the marital trusts’ assets

Malpractice claim against an estate was too uncertain to be deductible as of date of death and thus, the deduction would be based only on the amount actually paid by the estate Estate of Gertrude H. Saunders, et al. v. Comm’r, 136 T.C. No. 18 (4282011

Proskauer Rose LLP
-
USA
-
July 5 2011

In Saunders, a malpractice claim for $90,000,000 was filed against the decedent’s predeceased husband’s estate, alleging a breach of fiduciary duty by the decedent’s husband

Florida governor signed into law H.B. 469, which amends Florida Statutes 222.21(c) to provide that inherited IRAs are protected from claims of creditors of a debtor beneficiary H.B. 469, 2011 Leg. (Fla. 2011)

Proskauer Rose LLP
-
USA
-
July 5 2011

On May 31, 2011, Florida Governor Rick Scott signed H.B. 469 into law

Tax Court finds that life insurance proceeds were estate tax includible on account of decedent’s retained incidents of ownership, that annuities were estate tax includible, and that estate was liable for failure to file timely penalty Estate of Coaxum v

Proskauer Rose LLP
-
USA
-
August 5 2011

In Coaxum v. Commissioner, the Tax Court found that the decedent retained incidents of ownership in six life insurance policies, rendering their values includible in the gross estate, that the value of the annuities owned by the decedent was includible in the gross estate, and that the estate was liable for a failure to file timely penalty

< back next >