This Tax Court case addresses three of the issues “on the IRS radar” that frequently arise in estate and gift tax audits. (1) The decedent and her husband transferred marketable securities, an undivided interest in a building, and several other assets to an LLC in 2000. (2) The decedent made annual gifts of LLC interests to a Crummey trust in 2002-2007. (3) Following the decedent’s death in 2007, the estate beneficiaries made a loan to the estate to pay the estate taxes and the estate deducted the interest payments as an administration expense for estate tax purposes.
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