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Tax Court Rules for MPBA Clients in Rejecting Aggressive IRS Estate Tax Claim

In Estate of Purdue, T.C. Memo. 2015-249, the United States Tax Court denied an IRS attempt to disregard lifetime estate planning implemented by Barbara and Robert Purdue (the “Purdues”). MPBA attorneys, primarily Alan L. Montgomery and George W. Akers, advised Mr. and Mrs. Purdue with respect to the lifetime planning, and also represented Mrs. Purdue’s estate (the “Estate”) at the Tax Court. The Estate … Continue reading »

estatetaxplanning

IRS Announces Changes to Federal Transfer Tax Exemption

The IRS recently published Rev. Proc. 2014-61, which announces the annual inflation adjustments for certain federal tax provisions for 2015.  Among many other adjustments, the federal estate, gift and generation-skipping transfer tax exemption was increased from $5.34 million to $5.43 million.  Accordingly, the estate of a person dying in 2014 will only incur federal estate tax if the value of … Continue reading »

litigation

Fifth Circuit Decision Affirms Importance of Documenting Valuation Discounts

In the recent decision Estate of James A. Elkins, Jr. v. Comm’r, the Fifth Circuit Court of Appeals ruled that artwork owned by an estate was entitled to a significant 45% valuation discount, resulting in an over $14 million estate tax refund.  At the time of his death, James Elkins, the decedent, owned a 50% or 73% interest in 63 … Continue reading »