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Internal Revenue Service ignores trust amendment designed to create designated beneficiary
  • Sullivan & Worcester LLP
  • USA
  • August 1 2010

Private Letter Ruling 201021038 (May 28, 2010) shows the importance of careful drafting for a trust designated as the beneficiary of a retirement plan.


Strict privity requirement relaxed in New York: personal representative of estate may sue estate-planning attorney for negligence
  • Sullivan & Worcester LLP
  • USA
  • August 1 2010

In Estate of Schneider v. Finmann, 2010 NY Slip Op. 05281 (June 17, 2010), the Court of Appeals of New York relaxed its doctrine of strict privity, which holds that neither an estate nor its beneficiaries may maintain an action for malpractice against an attorney who advised a decedent regarding his estate plan.


U.S. stock owned by British citizen residing in Belgium included in taxable estate, but penalties abated
  • Sullivan & Worcester LLP
  • USA, Belgium
  • August 1 2010

In an interesting case before the U.S. Court of Appeals for the First Circuit, the estate of Noordin Charania appealed the IRS' determination that all of Noordin's Citigroup stock was includible in his estate and the IRS' refusal to abate an additional penalty assessed during audit.


Alison E. Lothes
  • Sullivan & Worcester LLP