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Tax court finds transfer of an interest in a limited partnership and timberland to an FLP was not includible in the decedent’s gross estate under Section 2036(a) because the transfer was a bona fide sale for adequate and full consideration
- Proskauer Rose LLP
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- USA
- -
- March 10 2010
This Tax Court decision provides another Section 2036 victory for the taxpayer by holding that assets transferred to an FLP were not includible in the decedent's gross estate under Section 2036(a) because the transfer was a bona fide sale for adequate and full consideration
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
- -
- USA
- -
- 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
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
- -
- USA
- -
- 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
U.S. government sues estate and donees of J. Howard Marshall II for unpaid gift taxes
- Proskauer Rose LLP
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- USA
- -
- 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
Court rescinds nonqualified disclaimer and denies gift tax liability
- Proskauer Rose LLP
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- 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
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- USA
- -
- November 5 2010
This case involves credits for tax on prior transfers under IRC 2013
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
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
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- 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
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