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IRS Allows Same-Sex Spouses to Recover Certain Transfer Tax Exemptions

The Internal Revenue Service recently released IRS Notice 2017-15 to provide special procedures for spouses in a same-sex marriage, or the executor of a same-sex spouse, to recalculate their gift and estate tax applicable...more

Taxpayer Prevails in Family Limited Liability Company Case

In a recent taxpayer victory, the Tax Court found in favor of the taxpayer with respect to three hotly contested gift and estate planning issues involving family limited liability companies. The Tax Court decided the case of...more

Fifth Circuit Court Reverses Tax Court Ruling on Fractional Interest Valuation Discounts

On September 15, the U.S. Court of Appeals for the Fifth Circuit reversed a 2013 Tax Court decision that had allowed only a nominal, 10% fractional interest discount for artwork included in a decedent’s estate....more

Tax Court Rules on Built-In Gains Discount and Appraiser Qualification

On February 11, 2014, the United States Tax Court issued a memorandum opinion (i) determining the proper method for valuing a holding company (i.e., an S or C corporation holding marketable securities or appreciated...more

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