Estate tax deductions were not limited to size of probate estate

Article Abstract:

The author discusses the Court of Federal Claims 1999 case of Estate of Snyder where the court interpreted IRC section 2053(c)(2) to mean that estate tax deductions can exceed the value of the probate estate if 'property subject to claims' includes nonprobate assets.

United States, Tax deductions

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Minority discount was applied to determine FMV before special-use valuation was calculated

Article Abstract:

The 1995 US 10th Circuit Court of Appeals' Estate of Hoover ruling properly held that an estate could reduce the fair market value of ranch property by a minority interest discount prior to calculating its special-use valuation. The Court ruled the estate could reduce its estate tax liability in this manner, holding that discounts can be applied to determine fair market value of a decedent's minority interest.

Special use valuation (Taxation)

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IRS aggregates QTIP and property owned outright for purposes of estate tax valuation

Article Abstract:

Two IRS technical advice memoranda state that qualified terminable interest property, such as closely held stock or partnership interests, should be aggregated with property owned outright for estate tax valuation purposes. The IRS also ruled against will provisions granting a beneficiary purchase rights to all of the estate's stock, disregarding such a provision for valuation purposes.

Trusts, Funds, Trusts, and Other Financial Vehicles, Corporations, Trusts (Law), Qualified terminable interest property, Qualified terminable interest property trusts

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