[Disclaimer: I am not an attorney. Please discuss any concepts with your attorney. I am not liable if any of these concepts are followed without consulting an attorney and turn out badly]. An attorney friend of mine sent an e-mail outlining several estate planning techniques which, in his opinion, are at risk of being reduced or eliminated. Here [...]
In a recent tax court case, Estate of Erma V. Jorgensen v. Commissioner, the judge detailed the challenges taxpayers must consider when having to justify the “bona fide sale” exception to I.R.C. 2036(a) when passive marketable securities, without active management, are involved. Taxpayers all like to receive discounts for lack of marketability and lack of control when [...]
