Fisher v. U.S. – Taxpayers Denied Gift Tax Annual Exclusion for Gifts of LLC Interests

We’re never happy to report IRS wins at KYEstates, but if we have to bring you news of taxpayer defeat, we like it when the defeat breaks no new ground in favor of the government. KYEstates previously discussed the denial of the annual exclusion for gifts of limited partnership interests in Price, which was sort of […]


Scylla and Charybdis: Valuation Discounts and Present Interests

The Petter case recently analyzed by KYEstate$ noted that valuation discounts are “a major goal . . . of contemporary estate planning” because they often “create the possibility of a more taxpayer-friendly valuation.” Petter cautioned, however, that valuation discounts are “often a major problem.”  It’s not surprising that the IRS would see valuation discounts as […]


FY2011 Green Book: Administration Plans on Estate Tax Return

Will the estate tax, like an old soldier, fade away? Or, like the same old soldier, will it return? The FY2011 Green Book, recently published by our friends in Washington, shows they are planning for the tax to return. The transfer tax sections of the FY2011 Green Book are looking awfully similar to what we […]