In the Estate of Christiansen v. Commissioner case, the decedent, who died in April 2001, left all property to her only child H through will that anticipated disclaimer and H disclaimed a portion of the gross estate valued at over $6,350,000. The will provided that 75% of the disclaimed portion would pass to a charitable foundation and 25% would pass to 20-year charitable lead annuity trust to pay the annuity to the foundation. H did not disclaim the contingent remainder interest in the property passing to the trust; the estate claimed deductions for values of property passing to trust to the extent of present value of annuity interest, and of property passing to the foundation. The IRS determined a higher value of the estate than reported on the return and disallowed the deductions for...
... the purpose of allowing the deduction for estate tax provided for in section 691(c)(1)(A). This sec... over the total amount excludable from the gross income of the surviving annuitant under section 72... section 691(b) which are allowable as deductions to his estate or to the beneficiaries of his estat...
... entitlement to marital and charitable deductions. While the estate's redetermination petition was p... the value of property included in the gross estate for estate tax purposes. The parties agree ...
Proposed regulations under Section 67 provide a uniform standard for identifying the types of costs incurred by estates or non-grantor trusts that are fully deductible in calculating adjusted gross income under Section 67(e)(1). Costs incurred by estates or non-grantor trusts that are unique to an estate or trust are not miscellaneous itemized deductions that are deductible only to the extent they exceed 2% of adjusted gross income. A public hearing is scheduled for November 14, 2007.
Non-resident aliens are subjected to many of the same estate taxes as US citizens. All property and interests held in the US is included in the gross estate of a non-resident alien and deductions for debts and losses are allowed. The marital deduction is allowed only if property is left to a spouse who is a US citizen. Estate tax treaties may alter the status of some non-resident aliens. Making lifetime transfers of intangible assets, transferring US property to foreign corporate ownership and using domestic trusts are ways to decrease tax liability.
.... There are several deductions from the gross estate in arriving at the taxable e...
...A person who is required to include in gross income for any taxable year an amount of income in... (c) of this section) over the deductions from the gross estate for claims which represent t...
... by deducting from the value of the gross estate the deductions provided for in this part. ....
..., the estate tax marital and charitable deductions, and state death taxes. . ********** . [ILLUSTRATI...To do so, especially for valuations of gross estates above the new $5 million exclusion, they m...
... was includible in the surviving spouse's gross estate under Sec. 2044. Inclusion in the transfer ... (along with other miscellaneous deductions) to 2% of adjusted gross income (AGI). Sec. 67(e)(...
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