Abstracts » Law

Uncle Sam no longer struck blind by heir's disclaimer to defeat tax liens

Article Abstract:

The authors discuss the U.S. Supreme Court 1999 case Drye, Jr. where the court held that federal tax liens were not affected by the disclaimer of an intestate heir's interest in an estate.

Taxation, Disclaimer of gifts, Tax liens

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IRS rules on QTIP IRA and conduit trust

Article Abstract:

The authors discuss IRS Revenue Ruling 2000-2 where the IRS authorized an election to treat an IRA and the IRA beneficiary trust as qualified terminable interest (QTIP) property. The ruling supercedes Revenue Ruling 89-89.

Commercial Banks, Investment Banking and Securities Dealing, Bank Individual Retirement Accounts, Analysis, Planning, Tax planning, Individual retirement accounts, Qualified terminable interest property, Qualified terminable interest property trusts, Tax elections

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Special-use valuation denied

Article Abstract:

The Tax Court in Estate of Thompson denied the estate the ability to value woodlands in accordance with the special-use valuation rules in IRC section 2032A. Those rules allow real property to be valued at lower farm or closely-held business property values rather than according to best use value. The valuation in Thompson fell short of the strict documentation requirements regarding comparable property values. Since IRS challenges in valuation cases are not unusual, detailed planning which tracks the law as closely as possible is advisable.

Personal Income Tax Administratn, Standards, Tax administration, Personal income tax, Valuation, Estate tax, Estate taxes, Real property, Real estate appraisal

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