New cases may knock out IRS opposition to defined value clauses

First, the U.S. Eight Circuit Court of Appeals decided Estate of Christiansen v. Comm’r (Nov. 2009), approving a formula disclaimer of estate assets that operated much like a defined value clause. Less than three weeks later, the U.S. Tax Court decided Estate of Petter v. Comm’r (T. C. Memo, Dec. 2009), which involved a defined [...]

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