Estate of Howard V. Moore, T.C. Memo 2020-40, addresses some important recurring issues, including:
- Land contributed to an FLP is included in the estate under § 2036(a)(1), with a lengthy discussion of the § 2043 “consideration offset” adjustment.
- A formula transfer to charity in light of the inclusion of additional assets in the gross estate following an estate tax audit is not given effect.
- Loan proceeds are gifts because notes documenting the loans are not treated as bona fide debt.
About The Speakers
Stephen R. Akers
Senior Fiduciary Counsel
Steve serves as Chair of the Firm’s Estate Planning Committee and works closely with clients in the Southwest Region regarding their estate and trust planning issues.
Ronald D. Aucutt
Senior Fiduciary Counsel
Ron is responsible for working with clients and their advisors to develop practical and efficient wealth transfer plans and for guiding the firm on fiduciary issues.