annual exclusion

Update: Forecasting the Fate of the Estate Tax

KYEstates readers, thanks for your patience. Yes, post volume has been down. That’s not because the transfer tax world has suddenly become boring – perish the thought. Rather, it’s been an extraordinarily busy month. First, your publisher visited his brother in Brooklyn and then went to his 10th Reunion. That was a little tough, because […]


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 […]