Valuation of IRAs
The estate tax valuation of an IRA is not entitled to a discount for the income tax liability resulting when distributions are made to the beneficiaries according to the court in Estate of Kahn v. Commissioner, 125 T.C. No. 11 (2005), which explained that a willing buyer would not have such liability and thus would pay full value.
Special thanks to Dave L. Cornfeld for bringing this case to my attention.
Posted in:
Estate Tax and New Cases