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
Business Related Issues
Corporations

De Los Santos v. Commissioner
156 T.C. No. 9

On April 12, 2021, the Tax Court issued its opinion in De Los Santos v. Commissioner, 156 T.C. No. 9. The underlying issue presented in De Los Santos v. Commissioner was whether the benefits (a split-dollar life insurance arrangement) received by the petitioners were received in their capacity as employees or shareholders, and, in turn, whether such economic benefits or taxable to the petitioner’s as ordinary compensation income or as a distribution under IRC § 301.

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Scott St. Amand April 12, 2021
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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

De Los Santos v. Commissioner
156 T.C. No. 9

On April 12, 2021, the Tax Court issued its opinion in De Los Santos v. Commissioner, 156 T.C. No. 9. The underlying issue presented in De Los Santos v. Commissioner was whether the benefits (a split-dollar life insurance arrangement) received by the petitioners were received in their capacity as employees or

Read More »
Scott St. Amand April 12, 2021