Estate Tax Issues
Estate Tax

Estate of Levine v. Commissioner
158 T.C. No. 2

On February 28, 2022, the Tax Court issued the full opinion in Estate of Levine v. Commissioner (158 T.C. No. 2). The primary issues presented in Estate of Levine v. Commissioner were whether the taxpayer made a voluntary inter vivos transfer (yep); whether the taxpayer retained the right—either alone or in conjunction with her attorney-in-fact—to designate who could possess or enjoy property transferred to irrevocable life insurance trust or the income from it (thereby precluding

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Scott St. Amand June 8, 2022
Income Tax Issues
Estate Tax

Estate of Morrissette v. Commissioner
T.C. Memo. 2021-60

On May 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Morrissette v. Commissioner (T.C. Memo. 2021-60). The primary issue presented in Estate of Morrissette v. Commissioner was whether IRC § 2036 or IRC § 2038 applies to recapture significant inter vivos transfers made as part of the split-dollar agreements, and, if not, whether the special valuation rule of IRC § 2703 applies to require that the valuation disregard a

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Scott St. Amand May 12, 2021
Income Tax Issues
Deathbed Transfers

Estate of Moore v. Commissioner
T.C. Memo. 2020-40

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Moore v. Commissioner (T.C. Memo. 2020-40). The general issues before the court in Estate of Moore v. Commissioner were (1) whether the petitioner’s complex estate plan actually reduced the size of his taxable estate and (2) whether the petitioner’s estate planning resulted in unintended taxable gifts. The Tax Court answers these questions through a most thorough analysis of IRC

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Scott St. Amand April 7, 2020
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Estate of Levine v. Commissioner
158 T.C. No. 2

On February 28, 2022, the Tax Court issued the full opinion in Estate of Levine v. Commissioner (158 T.C. No. 2). The primary issues presented in Estate of Levine v. Commissioner were whether the taxpayer made a voluntary inter vivos transfer (yep); whether the taxpayer retained the right—either alone or

Read More »
Scott St. Amand June 8, 2022

Estate of Morrissette v. Commissioner
T.C. Memo. 2021-60

On May 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Morrissette v. Commissioner (T.C. Memo. 2021-60). The primary issue presented in Estate of Morrissette v. Commissioner was whether IRC § 2036 or IRC § 2038 applies to recapture significant inter vivos transfers made as

Read More »
Scott St. Amand May 12, 2021

Estate of Moore v. Commissioner
T.C. Memo. 2020-40

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Moore v. Commissioner (T.C. Memo. 2020-40). The general issues before the court in Estate of Moore v. Commissioner were (1) whether the petitioner’s complex estate plan actually reduced the size of his taxable estate

Read More »
Scott St. Amand April 7, 2020